ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 1 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

Controlled Document if Viewed On-Line. If Printed, Valid for 24 Hours from Print 

Date/Time. Print Date/Time 5/30/20113/26/20082/8/2008 11:22 AM1:46:57 PM2:51:30 

PM

a

National Emission Standards for Hazardous Air 

Pollutants for Primary Aluminum Reduction Plants

POTLINE PRIMARY EMISSION CONTROL SYSTEM

Start up, Shut Down, and Malfunction Plan

Alcoa Inc.

Rockdale Operations

Rockdale, Texas

Prepared by:

Alcoa Inc.

4069 Charles Martin Hall Road

PO Box 472

Rockdale, Texas 
 ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 2 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

Controlled Document if Viewed On-Line. If Printed, Valid for 24 Hours from Print 

Date/Time. Print Date/Time 5/30/20113/26/20082/8/2008 11:22 AM1:46:57 PM2:51:30 

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TABLE OF CONTENTS

PAGE

TABLE OF CONTENTS 2

1.0 INTRODUCTION 3

2.0 STARTUP PLAN 3

3.0 SHUTDOWN PLAN 6

4.0 CORRECTIVE ACTION PLAN 7

LOW AIR FLOW

LOW ALUMINA FLOW

MAINTENANCE OF CONTINUOUS MONTORING SYSTEM

5.0 MALFUNCTION PLAN 11

LOSS OF POTLINE POWER FOR AN EXTENDED PERIOD

CATASTROPHIC FAILURE OF FUME CONTROL EQUIPMENT 

6.0 VISIBLE EMISSION PLAN 12

APPENDIX A FLOW CHART 13
 ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 3 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

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1.0 INTRODUCTION

This Startup, Shutdown, Malfunction (SSM) Plan meets the requirements of the Primary 

Aluminum NESHAP. This plan contains procedures to be used during periods of startup, 

shutdown, and malfunction as well as procedures for corrective action for the primary control 

devices of potlines 3-8 at Rockdale Operations. This plan will be made available to the permitting 

authority upon request. 

2.0 STARTUP PLAN

A startup or restart is defined as the process of re-energizing an idled section(s) of aluminum 

reduction cells that is serviced by an idled control device(s). The startup or restart begins when 

the first idled reduction cell has liquid bath added to it. The startup or restart concludes when the 

last of the number of pots scheduled for startup or restart has been energized and liquid bath 

added. 

This plan is to be followed for the startup or restart of the portion of the potline served by any 

emission control device. If this plan is followed, the semi-annual report will note that it was 

followed. If this plan is not followed, each event is to be reported to the environmental department 

within 1 day of the event. Within 2 days of the event, it is to be reported to the regulatory 

authorities, a notification letter posted within 7 days, and revisions to this plan prepared and 

submitted within 45 days of the non-conforming event. Revisions to the plan are to identify 

revised procedures for operating and maintaining the source during SSM events and a program of 

corrective action for similar events in the future. Revisions to this plan must be retained for 5 

years. 

2.1 Actions for Potlines with Wet Scrubber (Lines 3, 4, and 6)

1. The Operator is to assure that prior to adding liquid bath to the first pot water flow has 

been established in a wet scrubber(s). The Operator is responsible for starting water flow 

and airflow to the appropriate number of scrubbers to ensure the ratio of operating pots to 

wet scrubbers does not exceed 24:1. 

2. During start-ups of potlines idled prior to the compliance date established in 40 CFR 63, 

Subpart LL and restarted after the compliance date established in 40 CFR 63, Subpart LL,

the operator is to assure that the ratio of pots operating to wet scrubbers on line does not 

exceed 24:1. If this ratio exceeds 24:1, then additional wet scrubber towers are to be put 

on line. (This ratio of a minimum of 24 pots for each wet scrubber tower applies only 

during start-up and re-start conditions to assure a consistently high minimum process gas 

flow rate to all pots that have been started or re-started.)

3. During start-ups of potline portions, the operator is to assure that the ratio of pots 

operating to wet scrubbers on line does not exceed 24:1. The operator is to also assure 

that operating parameters during the start-ups of potline portions do not fall below the 

lower limits computed from the number of operating components of the control device. 

The limits will be determined and compared using the calculations below on a daily basis:
 ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 4 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

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Number of Operating Scrubbers =

24

Number of OperatingCells

When the computed values are 1.0, the number of scrubbers to be operated is 1. Values greater than whole numbers 

shall be rounded to the next larger whole number (e.g. 1.1 = 2 operating scrubbers).

Parametric value(s) = 

Number of Operating Scrubbers

Potline Parametric Limit

4. The Start-Up is to be logged. Log entries are to include the time, date, duration of event, 

extraordinary actions taken beyond the scope of this plan, and initials or a signature. 

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

semi-annual report for that period.

5. Records of the start-up are to be retained for five (5) years.

2.2 Potline w/ Electrostatic Precipitator (Lines 3 and 6)

1. The Operator is to assure that prior to adding liquid bath to the first pot, an electrostatic 

precipitator has been energized and water flow has been established in a wet scrubber. 

The Operator is responsible for starting water flow and airflow to the appropriate number 

of scrubbers to ensure the ratio of operating pots to wet scrubbers on line does not 

exceed 24:1. 

2. During start-ups of potlines idled prior to the compliance date established in 40 CFR 63, 

Subpart LL and restarted after the compliance date established in 40 CFR 63, Subpart LL,

the operator is to assure that the ratio of pots operating to wet scrubbers on line does not 

exceed 24:1. If this ratio exceeds 24:1, then additional wet scrubber towers are to be put 

on line. (This ratio of a minimum of 24 pots for each wet scrubber tower applies only 

during start-up and re-start conditions to assure a consistently high minimum process gas 

flow rate to all pots that have been started or re-started.)

3. During start-ups of potline portions, the operator is to assure that the ratio of pots 

operating to wet scrubbers on line does not exceed 24:1. The operator is to also assure 

that operating parameters during the start-ups of potline portions do not fall below the 

lower limits computed from the number of operating components of the control device. 

The limits will be determined and compared using the calculations below on a daily basis:

Number of Operating Scrubbers =

24

Number of OperatingCells

When the computed values are 1.0, the number of scrubbers to be operated is 1. Values greater than whole numbers 

shall be rounded to the next larger whole number (e.g. 1.1 = 2 operating scrubbers).

Parametric value(s) = 

Number of Operating Scrubbers

Potline Parametric Limit

4. The Start-Up is to be logged. Log entries are to include the time, date, duration of event, 

extraordinary actions taken beyond the scope of this plan, and initials or a signature. 

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

semi-annual report for that period.

5. Records of the start-up are to be retained for five (5) years.
 ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 5 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

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2.3 Potline w/ A-398 Control Systems (Lines 5, 7, & 8)

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 airflow to the appropriate number of A-398 compartments to 

ensure that the ratio of operating pots to operating A-398 compartments does not exceed 

16:1. 

2. During start-ups of potlines idled prior to the compliance date established in 40 CFR 63, 

Subpart LL and restarted after the compliance date established in 40 CFR 63, Subpart LL,

the operator is to assure that the ratio of pots operating to A-398 compartments on line 

does not exceed 16:1. If this ratio exceeds 16:1, then additional A-398 compartments are 

to be put on line. (This ratio of a minimum of 16 pots for each A-398 compartment applies 

only during start-up and re-start conditions to assure a consistently high minimum process 

gas flow rate to all pots that have been started or re-started.)

3. During start-ups of potline portions, the operator is to assure that the ratio of pots 

operating to A-398 compartments on line does not exceed 16:1. The operator is to also 

assure that operating parameters during the start-ups of potline portions do not fall below 

the lower limits computed from the number of operating components of the control device. 

The limits will be determined and compared using the calculations below on a daily basis:

Number of A-398 Compartments =

24

Number of OperatingCells

When the computed values are 1.0, the number of scrubbers to be operated is 1. Values greater than whole numbers 

shall be rounded to the next larger whole number (e.g. 1.1 = 2 A-398 Compartments).

Parametric value(s) = 

Number of Operating Scrubbers

Potline Parametric Limit

4. The Start-Up is to be logged. Log entries are to include the time, date, duration of event, 

extraordinary actions taken beyond the scope of this plan, and initials or a signature. 

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

semi-annual report for that period.

5. Records of the start-up are to be retained for five (5) years. 

2.4 Potline w/ Baghouse Control Systems (Lines 3 & 4)

1. The Operator is to assure that prior to adding liquid bath to the first pot, Baghouse control 

system has been started. The Operator is responsible for ensuring that airflow to the 

baghouse compartments has begun and that the baghouse is operating within the 

established control device operating parameters (e.g. Examples might be acfm, fan amps, 

pressure drop, visible emissions, etc). 

2. The Start-Up is to be logged. Log entries are to include the time, date, duration of event, 

extraordinary actions taken beyond the scope of this plan, and initials or a signature. 

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

semi-annual report for that period.

3. Records of the start-up are to be retained for five (5) years. 
 ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 6 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

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If compliance has not previously been determined, compliance will be demonstrated within 180 

days after the completion of the startup or restart. The appropriate limits for the parameters will 

be determined within 180 days after the completion of the startup or restart.

3.0 SHUTDOWN PLAN

A shutdown 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 Primary Control 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 shutdown 

concludes 48 hours after service of electrical power has been discontinued.

Appropriate limits for parametrics during a shutdown will be determined from the ratio of pots 

operating to on-line primary control devices1. The operator is to assure that operating parameters 

during the shutdowns of a potline or portions of a potline do not fall below the lower limits 

computed from the number of operating components of the control device. The limits will be 

determined and compared using the calculations below on a daily basis:

Number of Operating Fume Control Devices =

RatioValue

Number of Operating Cells

When the computed values are 1.0, the number of scrubbers to be operated is 1. Values greater than whole 

numbers shall be rounded to the next larger whole number (e.g. 1.1 = 2 A-398 Compartments).

Parametric value(s) = 

Number of Operating Fume Control Devices

Potline Parametric Limit

The plan is to be followed for shutdown of an entire potline or a portion of a potline served by any 

emission control device. If this plan is followed, the semi-annual report will note that it was 

followed. If this plan is not followed, the shutdown plan deviations are to be reported to the 

environmental department within 1 day of the shutdown. Within 2 days of the shutdown, the 

deviation is to be reported to the regulatory authorities, a notification letter posted within 7 days, 

and revisions to this plan prepared and submitted within 45 days of the non-conforming shutdown 

activities. Revisions to the plan are to identify revised procedures for operating and maintaining 

the source during shutdowns and a program of corrective action for similar shutdowns in the 

future. Revisions to this plan must be retained for 5 years. 

If only a portion of the potline served by a single control device is shut down, the operator will 

again target the ratio of pots operating to fume control equipment to be 16:1 or less for potlines 

controlled by A-398 systems and 24:1 for potlines controlled by wet scrubbers.

 

1 Wet scrubber ratio = 24:1 and A-398 ratio = 16:1
 ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 7 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

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3.1 Shutdown Actions

1. The Operator is to assure that throughout the shutdown, sufficient emission controls are 

kept operating such that a minimum ratio of 16:1 or less operating cells to control devices 

is maintained for potlines controlled by A-398 systems and a ratio of 24:1 or less 

operating cells to control devices is maintained for potlines controlled by wet scrubbers.

2. The Operator may shut down A-398 compartments any time after the 48-hour period, 

because the liquid contents of the reduction cells will be frozen and gaseous emissions 

will cease after 48 hours without electrical power.

3. The Operator is responsible for logging the Shutdown in the SSM log. 

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

4.0 CORRECTIVE ACTION PLAN

4.1 Low Air Flow (All potlines)

Low air flow is defined as air flow conditions that generate a daily cumulative fan amp-hour 

parametric value that is below the parametric limit established for a control device. It is 

determined by a comparison of the cumulative fan amp-hours for each Fume Control Device over 

the potroom cycle to the established cumulative fan amp hour parametric limit established for the 

fume control device. The following Corrective Action Plan must be initiated within one hour of first 

becoming aware of a parametric exceedance. Failure to initiate and adhere to this Corrective 

Action plan within an hour of first becoming aware of an exceedance will result in a violation. 

Both parametric exceedances and violations must be reported on the semi-annual report.

Examples of low air flow conditions include, but are not limited to, outages that result in control 

device downtime or simultaneous multiple control device downtime that generates a daily 

cumulative fan amp-hour parametric value that is below established limits; motor control failure; 

motor failure; fan failure. 

4.1.1 Actions to be followed:

1. The Operator is to log the time that he/she first became aware of the parametric 

exceedance and the time at which he/she initiated the corrective action plan. 

2. The Operator is to confirm the system status, noting which control device 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 in the SSM log. 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 maintenance 

logs.

7. Records of the exceedance are to be retained for five (5) years. 
 ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 8 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

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4.2 Low Alumina Flow (Lines 5, 7, & 8)

Low alumina flow is defined as a cumulative rotary vane feeder-hour value lower than the 

parametric limit established for a particular control device. Failure to initiate and adhere to this 

Corrective Action plan within an hour of first becoming aware of an exceedance will result in a 

violation. 

Examples of low flow conditions include, but are not limited to; motor failure; motor control failure; 

drive assembly failure; secondary ore feed components; unexpected failure of the primary air 

gravity conveyor (a.k.a.- feed air slide) or one of its components such as the canvas membrane or 

the primary blower and reductions in alumina flow due to unplanned outages that generates a 

daily cumulative rotary vane feeder-hour parametric value that is below established limit. When 

an operator first becomes aware of a cumulative rotary vane feeder-hour parametric value below 

an established limit, the actions in section 4.2.1 are to be initiated.

4.2.1 Actions to be followed: 

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 confirm the system status, noting which control device 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 in the SSM log. 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 any 

maintenance logs.

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

The 7th exceedance of a parametric limit in the semi-annual reporting period will result in a 

violation. Both exceedances and violations must be reported on the semi-annual report.

4.3 Low Water Flow (Lines 3,4,& 6)

Low water flow is defined as a 24-hour cumulative water flow (e.g. gallons/24-hours) value lower than 

the parametric limit established for a particular wet scrubber (system or device?). Examples of 

situations causing low flow conditions may include, but are not limited to; unexpected pump 

failures, piping breaks, failure of one or more water system components and reductions in water 

flow due to unplanned wet scrubber outages. When an operator first becomes aware of a 24-

hour cumulative water flow (e.g. gallons/24-hours) parametric value below an established limit, the 

actions in section 4.3.1 are to be initiated.

4.3.1 Actions to be followed: 

1. The operator is to confirm the system status, noting which wet scrubber towers are in a 

no flow or reduced flow condition. The operator is to log the time that the condition was 
 ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 9 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

Controlled Document if Viewed On-Line. If Printed, Valid for 24 Hours from Print 

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first noticed or reported and also log the time at which he/she first began to respond to 

check the system status.
 ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 10 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

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

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 report for that period.

The 7th exceedance of a parametric limit in the semi-annual reporting period will result in a 

violation. Both exceedances and violations must be reported on the semi-annual report.

4.4 Electrostatic Precipitator Primary Voltage (Lines 3 and 6)

An electrostatic precipitator primary voltage parametric limit excursion is defined as a 48-hour 

cumulative primary voltage value that is lower than the parametric limit established for a particular 

electrostatic precipitator. Examples of situations causing low voltage conditions may include, but 

are not limited to; material build-up in precipitator hopper causing a ground fault; cracked or 

broken insulator; ESP internal failure; transformer/rectifier failure (T/R set); controller and/or 

circuitry failure; rapper failure; and reductions in primary voltage due to unplanned electrostatic 

precipitator outages. When an operator first becomes aware of a precipitator primary voltage 

parametric value below an established limit, the actions in section 4.4.1 are to be initiated.

4.4.1 Actions to be followed: 

1. The operator is to confirm the system status, noting which eletrostatic precipitator(s) 

are in a reduced voltage 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 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 other 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 initial or sign the log entry. 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. 

The 7th exceedance of a parametric limit in the semi-annual reporting period will result in a 

violation. Both exceedances and violations must be reported on the semi-annual report.
 ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 11 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

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4.5 Electrostatic Precipitator Secondary Current (Lines 3 and 6) 

An electrostatic precipitator secondary current parametric limit excursion is defined as a 48-hour 

cumulative secondary current value that is lower than the parametric limit established for a 

particular eletrostatic precipitator. Examples of situations causing low current conditions may 

include, but are not limited to; material build-up in precipitator hopper causing a ground fault; 

cracked or broken insulator; ESP internal failure; transformer/rectifier failure (T/R set); controller 

and/or circuitry failure; rapper failure; and reductions in secondary current due to unplanned 

electrostatic precipitator outages. When an operator first becomes aware of a precipitator 

secondary current parametric value below an established limit, the actions in section 4.5.1 are to 

be initiated.

4.5.1 Actions to be followed: 

1. The operator is to confirm the system status, noting which electrostatic precipitator(s) 

are in a reduced secondary current 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 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 other 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 initial or sign the log entry. 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. 

The 7th exceedance of a parametric limit in the semi-annual reporting period will result in a 

violation. Both exceedances and violations must be reported on the semi-annual report.

4.6 Malfunction of Continuous Monitoring System 

Malfunctions could include power interruptions, PLC/PC malfunctions, and PLC- PC 

communication problems. Malfunctions caused by a catastrophic failure of the fume control 

equipment may also result in loss of the continuous monitoring system.

The plan is to be followed for the repair of 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 within 1 day to the environmental department. Within 2 days of the shutdown, the 

deviation is to be reported to the regulatory authorities, 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 monitoring system and the time at which he/she initiated the corrective action plan. 
 ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 12 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

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4.6.1 Actions to be followed: 

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 personnel 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. 

4. The Operator is responsible for logging the repair on the SSM log. 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 appropriate entries into any 

maintenance logs.

Records of the repair of the continuous monitoring system are to be retained for five (5) years.

5.0 MALFUNCTION PLAN

5.1 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 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 within 2 days, and 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.

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

lightning strike, a loss of electrical power, an earthquake, a tornado, or a system fire that results in 

uncontrolled emissions. 

5.1.1 Actions to be followed:

1. The operator is to log the time that the condition was first noticed or reported and log 

the time at which he/she first began to respond.

2. As soon as the situation has become stable and hazards have been cleared, the 

Operator is to confirm the system status, noting which fume treatment system 

components are either off line or otherwise impaired. 

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

personnel.

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 malfunction on the SSM log. 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.

6. Maintenance personnel are responsible for making appropriate entries into any 

maintenance logs.

7. Records of the malfunction are to be retained for five (5) years.
 ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 13 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

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6.0 VISIBLE EMISSION PLAN

Atypical visible emissions are defined as the presence of visible emissions indicative of abnormal 

fume control device operation. The following Visible Emission Plan must begin within one hour of 

observing visible emissions that are atypical of normal operations. The failure to initiate this plan 

within one hour will result in a violation. Violations must be reported on the semi-annual report.

Failure to perform daily visual checks is a violation and must be reported to the environmental 

department immediately.

6.1 Visible Emissions Actions

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 repair(s), to remedy the situation in a safe, efficient, 

and timely manner.

5. The Operator is responsible for logging the corrective action on the SSM log. This will 

include logging the time, date, duration, any actions taken 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 visible emissions are to be retained for five (5) years.
 ROCKDALE OPERATIONS –ENVIRONMENTAL PAGE 14 Of 14

 Document Number: ENV-PLN-04

 Title: Potline Start Up, Shut Down, and Malfunction Plan

Controlled Document if Viewed On-Line. If Printed, Valid for 24 Hours from Print 

Date/Time. Print Date/Time 5/30/20113/26/20082/8/2008 11:22 AM1:46:57 PM2:51:30 

PM

APPENDIX A

Flowchart

63.850 Notification, reporting, and record keeping requirements. 

Start corrective

Action within

one hour

Atypical Visible

Emissions

YES

NO

Document

Violation –notify 

environmental 

department

Parametrics

Measurements

Over

Exceedance

Limit?

Corrective

Action within

YES One Hour

Violation –

notify envir.

NO

Report semiannually to 

agency

YES

7

th within

Six Months

Violation –

notify Envir. 

YES Dept.

Catastrophe

Reaction 

Plan 

Followed

Violation

Startup, Shutdown,

Malfunction and

Corrective Action

Plans

Followed

Plan?

Report Plan 

Followed

YES

Report within

two days.

Letter within

7 days

Revise & submit

plan in 45 days

NO

Recordkeeping

Parametric 

Limit 

Excursion

Yes Report semiannually to 

agency

NO

NO

YES