### 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 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

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:

Alc oa 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 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

PM 

## T ABLE OF 

## C ONTENTS

PAGE

TABLE OF CONTENTS 2

1.0 INTRODUCTION 3

2.0 STARTUP PLAN 3

3.0 SHUTDOWN PLAN 6

4.0 CORRECTIVE ACTI ON PLAN 7
LOW AIR FLOW

LOW ALUMINA FLOW

MAINTENANCE OF CONTI NUOUS MONTORING SYST EM

5.0 MALFUNCTION PLA N 11

LOSS OF POTLINE POWE R FOR AN EXTENDED PE RIOD

CATASTROPHIC FAILURE OF FUME CONTROL EQUI PMENT

6.0 VISIBLE EMISSION PLA N 1 2

APPENDIX A FLOW C HART 13

### ROCKDALE OPERATIONS

– ENVIRONMENTAL PAGE 3 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 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

PM 

### 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 co rrective 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 idl ed 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 ac tion for similar events in the future. Revisions to this plan must be retained for 5

years.

2.1 Actions for Pot lines w ith 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 pri or 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 dur ing 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

Controlled Document if Viewed On

- Line. If Printed, Valid for 24 Hours from Print

Date/Time. Print Date/Time 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

PM Number of Operatin g Scrubbers =

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 valu e(s) =

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/ Electrost atic Precipitator (Lines 3 and 6)

1. The Operator is to assure that prior to adding l iquid 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 opera tor 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 =

When the computed values are 1.0, the number of scrubbers to be operated is 1. Values greater than whole numbe rs shall be rounded to the next larger whole number ( e.g. 1.1 = 2 operating scrubbers ).

Parametric value(s) =

4. The Start

- Up is to be logged. Log entries are to include the time, date, duration of event, extraordinary actions take n 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

Controlled Document if Viewed On

- Line. If Printed, Valid for 24 Hours from Print

Date/Time. Print Date/Time 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

PM 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,

S ubpart 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 compar tments 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 =

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) =

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

sy stem 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,

press ure 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 applic able 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

Controlled Document if Viewed On

- Line. If Printed, Valid for 24 Hours from Print

Date/Time. Print Date/Time 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

PM 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 c ontents 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 af ter 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 devices 1 . 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 l imits will be determined and compared using the calculations below on a daily basis:

Number of Operating Fume Control Devices =

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) =

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 o f 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 ar e 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 ser ved 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

Controlled Document if Viewed On

- Line. If Printed, Valid for 24 Hours from Print

Date/Time. Print Date/Time 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

PM 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 a nd 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 a mp

- 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 awar e 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

- annu al 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 e stablished 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) year s.

### ROCKDALE OPERATIONS

– ENVIRONMENTAL PAGE 8 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 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

PM 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; unexpe cted 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 feede r

- 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 foll owed:

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 o ff 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, efficien t, 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. Mainte nance 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 7 th exceedance of a parametric limit in the semi

- annual reporting period will result in a

violat ion. 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 f ollowed:

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

Date/Time. Print Date/Time 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

PM first noticed or reported and also log the time at which he/she fi rst 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

Controlled Document if Viewed On

- Line. If Printed, Valid for 24 Hours from Print

Date/Time. Print Date/Time 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

PM 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 malfunct ion 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, ex traordinary 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 retaine d 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 7 th 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 primar y 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 o perator 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 eletro static 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 res ponse, 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 rem edy 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 th e 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 7 th 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

Controlled Document if Viewed On

- Line. If Printed, Valid for 24 Hours from Print

Date/Time. Print Date/Time 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

PM 4.5 Electrostatic Precipitator Secondary Current 

### ( Lines 3 and 6 

### )

An electrostatic precipitator secondary current par ametric 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 n ot 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 cur rent 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 followe d:

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 malf unction 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 7 th 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 Monitori ng System

M alfunctions 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 depar tment. 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. Th e 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

Controlled Document if Viewed On

- Line. If Printed, Valid for 24 Hours from Print

Date/Time. Print Date/Time 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

PM 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 th is 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 da ys 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 syste m 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 st able 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

personne l.

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 loggin g 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

Controlled Document if Viewed On

- Line. If Printed, Valid for 24 Hours from Print

Date/Time. Print Date/Time 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

PM 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 with in 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 check s 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. T he 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 re pair(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,

an d 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 5/30/2011 3/26/2008 2/8/2008 11:22 AM 1:46:57 PM 2:51:30

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? Corr ective

Action within

One Hour YES Violation

– notify envir. NO

Report semi

annually to

agency YES

7 th within

Six Months Violation

– notify Envir. Dept. YES

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 semi

annually to

agency NO

YES