## 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: 0 8

- 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 f low then corrective actions must be initiat ed 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 serv iced 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 sto pping 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 re

start, 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 sta rting 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

- star t 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 Wenatch ee 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 initi ated within 1 hour

. A shut

- down is defined as the process of allowing a complete anode baking f urnace(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 u se 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

a ssure 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 elapse d. 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 Rev ision: 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 initi ated 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 mai ntenance 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 situat ion 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 repor ted 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 th e event of low flow of alumina through this fume control system (device) the following malfunction and corrective action plan, then corrective actions must be initi ated within 1 hour

. Examples of low flow conditions include, but are not limited to; unex pected 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 th at 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 t hat 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 s ystem 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 Envir onmental Department.

### MALFUNCTION/CORRECTIVE ACTION PLAN Wenatchee Operations

- ALCOA Last Revision: 08

- 0 6

- 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 initiat ed 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) h ours 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 compartmen ts 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

ma intenance 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 situati on 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 reporte d 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 in itial 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), eq uipment 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 initiat ed within 1 hour E xamples 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 haza rds 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 En vironmental 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 emis sions, dusting stack(s), for this fume control system (device )
, then corrective actions must be initiat ed within 1 hour Examples of visible emissions or dusting stack(s) include, but are not limited to; continuous visible emissions noted by the Operator fr om 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 malf unction 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 in itiated within 1 hour. Aligned various action plans. KAK