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From: "Robert Strieter" <bstriete@aluminum.org>

To: Donnalee Jones/RTP/USEPA/US@EPA

Cc: Rochelle Boyd/RTP/USEPA/US@EPA, "mikepalazzolo" <michael.palazzolo@alcoa.com>, <jperdion@bakerlaw.com>

Date: 02/18/2010 01:12 PM

Subject: RE: recommendations for the draft list of SSM work practices

Donna:

Attached for your review and consideration is our compilation of recommendations (in track changes/redline format) to revise the draft list of PMACT SSM work practices that we received in December. We 

appreciate the opportunity to review the list and will be happy to meet with you and your colleagues to 

further discuss the recommendations we have provided.

Regards,

Bob

Bob Strieter

VP - EHS

The Aluminum Association

bstriete@aluminum.org

703 358-2980

cell 571 224-6598

1525 Wilson Blvd

Suite 600

Arlington, VA 22209

-----Original Message-----

From: Jones.Donnalee@epamail.epa.gov [mailto:Jones.Donnalee@epamail.epa.gov] 

Sent: Friday, December 11, 2009 1:37 PM

To: Robert Strieter

Cc: boyd.Rochelle@epa.gov

Subject: draft list of SSM work practices; article and calcs to estimate fluoride from start-up

Bob - I appreciate the call this a.m. Here are the items I talked about on the phone with you.

(1) A Word file (draft-list of WP's) which is the beginning of my list of potential work practices that Ive 

accumulated from a couple of industry sources. As I explained on the phone, Id like to get a full list of all 

the possibilities, i.e., any work practice that any facility is using, so that we can turn it into a "check the 

box" form to be distributed to the entire industry. In order to add start-up operations to the NESHAP we 

need to do a "MACT floor" which means first finding out whats being done by everyone in the industry, if 

at all possible. We'd like to sene the survey out by the end of January, so the sooner as you can get this 

back to me the better. The facilities can send their comments directly to me or you can collect them and 

send them all at once. At this point, we dont need to know who is doing each work practice.

(2) The other files pertain to the theoretical procedure that was presented to EPA for estimating start-up 

emissions in terms of lb/pot-day fluoride emissions. Ive put all the files in one pdf for easy email 

distribution and then also attached the actual spreadsheets. I, myself, find it informative to see how each 

calculation is done, which is a feature of Excel (press F2 on any number to see all the terms involved the 

calculation). I would be interested to know if anyone had any comments on this method or had another 
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method of estimating F emissions. Also, the article says (pg 7) that the equations were only checked 

against emission data from one cell, so it would be good to find out if there have been any other checks 

done. 

Have a good holiday if I dont speak to you before then. Ill be here most of the time with a few days/hours 

off here and there.

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Regards,

Donna Lee Jones, Ph.D.

U. S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division / Metals & Minerals Group (D243-02)

Research Triangle Park, NC 27711 Tele: (919) 541-5251 Fax (919) 541-3207

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
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December 11, 2009

Draft list of Potential SSM Work Practices for Primary Aluminum Facilities 

PLEASE ADD TO OR REVISE and return to EPA (jones.donnalee@epa.gov )

Potroom/potline Start-up

 Develop a potroom/potline start-up schedule before start-up, thato includes:

o Sufficient flexibility to restart potline in an orderly and controlled manner

o Target number of cells to be restarted per week

o Daily assessment of startup progress and any necessary schedule changes Schedule for 

daily start-up review

o Recordkeeping procedure for actual number of pots started per day Documentation 

procedures for start-up cell information

 Bring corresponding potroom/potline scrubbers on line prior to energizing first cell to be 

restarted up

o To the extent practicable Ssupply alumina at a rate to adequately scrub potentially 

higher concentration pot gases than during normal pot operation

o Respond to any sScrubber malfunctions according to the facility’s written SSM Plan

plan during start-up is .......

 Determine and maintain minimum air flows to energized pots to ensure fluoride capture per cell 

that are needed for proper operation during potroom/potline start-up

 Keep pots covered and vented to primary capture and control system as much as practicable

during start-up, and limit removal of covers or panels to only those pots being worked on at any 

given time. the number of pots that can be open at any given time to no more than (fill in 

the blank) open pots.

 Keep the primary capture and control system on and operating at all times during the startup.

 Limit the number of pots that can be re-started on a single day to no more than _____(fill in the 

blank) pots. Delete - number of pots restarted would be addressed in schedule discussed 

above.

Blank off affected ducts in the potline start-up section prior to start-up except for the few pots 

that will be initially started. Delete - this approach is not appropriate for all primary control 

system designs. The need to ensure adequate flow would instead is addressed by maintaining 

minimum air flows per cell as required above. 

 If air draft settings are available, place pots on high draft during addition of bath to a new pot or 

during pot startup. at bath up. and let these remain on high draft until the pots are sufficiently 

stable and crust is well sealed.

 Monitor pot lines frequently during start-up to identify “sick” pots that need attention and 

initiate countermeasures that need to be replaced.

 Procedures for attending to sick or unstable pot during start-up may include:

o Adjust cell voltage and feeding.

o Monitor and adjust anode current and liquid level.

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December 11, 2009

o Reduce temperature by adding solid or liquid bath or metal. Delete- This is same thing 

as “adjust liquid level” in bullet above.

o Reseal pot crust if needed to reduce emissions. Delete – Adding anode cover or 

otherwise trying seal make things worse depending on the problem (e.g., hot pot). 

 Shielding procedures during start-up: Delete - Not applicable as shielding procedures 

unchanged for startup

 Anode setting, and anode and butt delivery/transport procedures during start-up: Delete - Not 

applicable as procedures are unchanged for startup

 Potline reactor procedures during start-up– Delete – potline scrubber operation is already 

addressed above

 Tapping procedures during start-up Delete - Not applicable as procedures are unchanged for 

startup

 Procedures for cutting out a pot during start-up Delete - Not applicable as procedures are 

unchanged for startup

Anode Bake Furnace Start-up

Work practices are not relevant for startup of anode bake furnaces as startup does not cause excess 

emission compared to normal operation MACT limits. Emission control device must be operating 

prior to anode furnace startup to remove combustible materials from the furnace. 

 Startup procedures for anode bake furnace:

 Start-up for emission capture and control systems on anode bake furnace 

o Prior to start-up of anode bake furnaces is essential to remove combustible materials 

from the furnace

o After initial start-up of anode bake furnaces

 Operation of anode bake furnace to ensure proper furnace combustions conditions during first 

_________(fill in the blank) days/weeks of start-up

Paste Production Plants

Work practices are not relevant for startup of paste plant because startup does not cause excess 

emission compared to MACT requirements. Emission control device must be operating prior to paste 

plant startup as MACT and SSM Plan already require control device to be operating. 

 Startup procedures for paste production plants

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December 11, 2009

 Start-up for emission capture and control systems on paste production plants

o Prior to start-up 

o After initial start-up

 Xx

 xx

 Operation of paste production plants to ensure proper conditions during first _________(fill in 

the blank) days/weeks of start-up

Pitch Storage Tanks

Work practices are not relevant for startup of pitch storage tanks – these tanks are operational at all 

times because they contain pitch all the time. If the tank were emptied for some reason, “startup” 

would be identical to a normal loading activity where more pitch is added to the tank.

 Startup procedures for pitch storage tanks

o Xx

o Xx

 Start-up for emissions control systems on pitch storage tanks

o Prior to start-up 

 Xx

 xx

o After initial start-up

 Xx

 xx

 Operation of pitch storage tanks to ensure proper conditions during first _________(fill in the 

blank) days/weeks of start-up:

o Xx

o Xx

Shutdown Procedures

Only “work practice” applicable is to follow written SSM Plan, which requires operation of emission 

control device until shutdown is complete. 

 Potroom/potlines

o Xx

o xx

 Anode Bake Furnace

o Xx

o xx

 Paste Plants

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December 11, 2009

o Xx

o xx

 Pitch Storage Tanks

o Xx

o xx

Malfunction Procedures

Only “work practice” applicable is to respond to any malfunctions according to the facility’s written 

SSM Plan

 Potroom/potlines

 Anode Bake Furnace

 Paste Plants

 Pitch Storage Tanks

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