National Emission Standards for Hazardous Air 

Pollutants for Primary Aluminum Reduction Plants

Alcoa

Wenatchee Works

BAKE FURNACE PRIMARY EMISSION CONTROL 

SYSTEM

Start up, Shut Down, and Malfunction Plan

Prepared by:

Alcoa Inc.

6200 Malaga – Alcoa Hwy.

Malaga, WA 98828

Revision 1

June 12, 2008
START-UP PLAN

Wenatchee Operations - ALCOA Last Revision: 08-06-

12

Area: Anode Baking Furnaces - A-446 Fume Control Device

Condition: Start-Up/Re-Start/Fire Reversal of Baking Furnaces

In the event that a start-up, re-start or fire reversal of an anode baking furnace(s) served 

by this fume control system (device) creates or leads to a situation that causes operation 

outside of appropriate parametric ranges for process gas flow or alumina flow then 

corrective actions must be initiated within 1 hour.

A start-up or re-start is defined as the process initiating heating to sections of a ring 

furnace in which all sections of that furnace(s) have previously been at ambient 

temperature that is serviced by an A-446 Fume Control System (device). The start-up or 

re-start begins when the heating begins. The start-up or re-start concludes when fires 

begin to move to additional sections of the furnace(s). A fire reversal is defined as the 

process of stopping forward movement of all fires on a furnace(s) and reversing the 

direction of fire movement. The reversal begins when forward movement is stopped for 

all fire(s) on a furnace(s) and concludes when the fire(s) begin to move to sections of the 

furnace in the opposite direction. Appropriate limits for parametric ranges during a restart, start-up or reversal are determined by multiplying the limits for parametric ranges 

that have been approved for a furnace operation at a typical production rate by the ratio of 

the current actual production rate to the typical production rate.

1) The Operator(s) is to assure that prior to start-up or re-start that a fluidized bed of 

alumina has to be established in an A-446 compartment. The Operator is responsible 

for starting alumina flow and air flow to this first compartment. 

2) In the event of operation outside of approved parametric limits the Operator is to 

assure that sufficient reactors are running to maintain target inlet duct static pressure.

3) The start-up, re-start or fire reversal concludes when fire(s) begin to move. 

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

occur, it is to be reported in the semi-annual report by the Environmental Department.
SHUT-DOWN PLAN

Wenatchee Operations - ALCOA Last Revision: 08-06-

12

Area: Anode Baking Furnaces - A-446 Fume Control Device

Condition: Shut-Down of Baking Furnaces

In the event that a shut-down of a baking furnace(s) served by this fume control system 

(device) creates or leads to a situation that causes operation outside of appropriate 

parametric ranges for process gas flow or alumina flow then corrective actions must be 

initiated within 1 hour. 

A shut-down is defined as the process of allowing a complete anode baking furnace(s) to 

cool to ambient temperature. The shut-down begins when heating fuel has been 

intentionally discontinued for the purpose of a shut down or 24 hours after a sustained 

unintentional loss of heating fuel. The shut-down concludes 72 hours after use of heating 

fuel has been discontinued. Appropriate limits for parametric ranges during a shut-down 

are determined by maintaining appropriate inlet duct static pressure.

1) In the event of operation outside of approved parametric limits the Operator is to 

assure that sufficient reactors are running to maintain target inlet duct static pressure. 

2) After 72 hours of cooling time, the evolution of fumes from the furnace(s) will have 

ceased. A-446 compartments may be shut down any time after 72 hours have elapsed. 

3) Records of the shut-down are to be retained for five (5) years. Should an exceedance

occur, it is to be reported in the semi-annual report by the Environmental Department.
MALFUNCTION/CORRECTIVE ACTION PLAN

Wenatchee Operations - ALCOA Last Revision: 08-06-12

Area: Anode Baking Furnaces - A-446 Fume Control Device

Condition: Maximum Flow of Process Gas

In the event of maximum flow of process gas (a.k.a. - high air flow) through this fume 

control system (device) the following malfunction and corrective action plan , then 

corrective actions must be initiated within 1 hour. 

Examples of maximum flow conditions include, but are not limited to; conditions in the 

baking furnace requiring average reactor motor load above 430 amps for an eight hour

period. Or simultaneous multiple compartment downtime that requires an average reactor 

motor load above 430 amps for an eight hour period for on line reactors. 

1) The operator is to confirm the system status, noting which A-446 compartments are 

either off line or otherwise impaired. The operator is to log the time that the 

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

began to respond.

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) 

in events such as momentary loss of power.

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 and efficient 

manner. 

4) The system operator or proxy will be responsible for completing the SSM Log... 

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

years. Should an exceedance occur, it is to be reported in the semi-annual report by 

the Environmental Department.
MALFUNCTION/CORRECTIVE ACTION PLAN

Wenatchee Operations - ALCOA Last Revision: 08-06-12

Area: Anode Baking Furnaces - A-446 Fume Control Device

Condition: Low Flow of Alumina

In the event of low flow of alumina through this fume control system (device) the 

following malfunction and corrective action plan, then corrective actions must be initiated 

within 1 hour. 

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

pneumatic conveying system, 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 A-446 compartment outages that result in “static bed” 

conditions in one or more of the compartments in excess of 72 hours.

1) The operator is to confirm the system status, noting which A-446 compartments are in

A no feed (a.k.a.-static bed) 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.

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) 

in events such as momentary loss of power to the primary blower.

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 and efficient 

manner.

4) The system operator or proxy will be responsible for completing the SSM Log. . .

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

years. Should an exceedance occur, it is to be reported in the semi-annual report by

the Environmental Department.
MALFUNCTION/CORRECTIVE ACTION PLAN

Wenatchee Operations - ALCOA Last Revision: 08-06-12

Area: Anode Baking Furnaces - A-446 Fume Control Device

Condition: Loss of Parametric Monitoring - Fan Amps 

In the event of loss of fan amp signal(s) for this fume control system (device), then 

corrective actions must be initiated within 1 hour.

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

programmable logic controller, PLC, for more than six (6) hours in any twenty-four (24) 

hour period or loss of a measurement device component that results in an average eight 

hour fan amp reading above 430 amps.

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

A-446 compartments have suffered signal loss. The operator is to log the time that 

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

began to respond.

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 PLC in 

an event such as momentary loss of power.

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 and efficient 

manner.

4) The system operator or proxy will be responsible for completing the SSM Log. . .

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

years. Should an exceedance occur, it is to be reported in the semi-annual report by

the Environmental Department.
MALFUNCTION/CORRECTIVE ACTION PLAN

Wenatchee Operations - ALCOA Last Revision: 08-06-12 

Area: Anode Baking Furnaces - A-446 Fume Control Device

Condition: Loss of Parametric Monitoring - Rotary Vane Feeders 

In the event of loss of rotary vane feeder, RVF, signal(s) for this fume control system 

(device); corrective actions must be initiated within 1 hour.

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

programmable logic controller, PLC, for more than six (6) hours in any twenty-four (24) 

hour period or loss of a measurement device component that results in a RVF-hour 

parametric that is below acceptable limits.

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

A-446 compartments have suffered signal loss. The operator is to log the time that 

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

began to respond.

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 PLC in 

an event such as momentary loss of power.

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 and efficient 

manner.

4) The system operator or proxy will be responsible for completing the SSM Log. . .

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

years. Should an exceedance occur, it is to be reported in the semi-annual report by 

the Environmental Department.
MALFUNCTION/CORRECTIVE ACTION PLAN

Wenatchee Operations - ALCOA Last Revision: 08-06-12 

Area: Anode Baking Furnaces - A-446 Fume Control Device

Condition: Catastrophic Failure of Fume Control Equipment

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

control system (device), then corrective actions must be initiated within 1 hour

Examples of catastrophic failure include, but are not limited to; collapse of an A-446 unit 

or inlet duct, a direct lightning strike, an earthquake or a system fire that results in 

uncontrolled emissions.

1) As soon as the situation has become stable and hazards have been cleared, the 

operator or proxy is to confirm the system status, noting which A-446 compartments 

are either off line or otherwise impaired. The operator is to log the time that the 

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

began to respond.

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

maintenance, engineering and support personnel.

3) Personnel responding to the malfunction are to make repair(s), equipment 

replacement(s) or process change(s) to remedy the situation in a safe and efficient 

manner. In certain situations, location management may need to evaluate 

discontinuing the operation of baking furnace capacity. Such decisions may initiate 

appropriate Shut Down plans.

4) The system operator or proxy will be responsible for completing the SSM Log. .

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

years. Should an exceedance occur, it is to be reported in the semi-annual report by

the Environmental Department.
MALFUNCTION/CORRECTIVE ACTION PLAN

Wenatchee Operations - ALCOA Last Revision: 08-06-12 

Area: Anode Baking Furnaces - A-446 Fume Control Device 

Condition: Visible Emissions - Dusting Stack(s) 

In the event of visible emissions, dusting stack(s), for this fume control system (device),

then corrective actions must be initiated within 1 hour

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

continuous visible emissions noted by the Operator from any stack in the fume control 

device.

1) The operator is to confirm any report of a dusting stack(s) from any source including, 

but not limited to the daily visual checks made by the Operator. The operator is to log 

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

he/she began to respond. .

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

the appropriate compartment(s) shut down to make repairs.

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

in a safe and efficient manner.

4) The system operator or proxy will be responsible for completing the SSM Log. 

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

Should an exceedance occur, it is to be reported in the semi-annual report by the 

Environmental Department.

Revisions:

Revision Date Description Initials

Rev. 0 99-09-10 Original HMV

Rev. 1 08-06-12 Added cover page. Noted that corrective actions must 

be initiated within 1 hour. Aligned various action 

plans.

KAK