W ENATCHEE W ORKS

R EVISED S EPTEMBER 8, 2008 

# National Emission Standards for Hazardous Air Pollutants for Primary Aluminum Reduction Plants

Alcoa

Wenatchee Works

POTLINE PRIMARY EMISSION CONTROL SYSTEM Start up, Shut Down, and Malfunction Plan

Prepared by:

Alcoa 6200 Malaga Hwy. Malaga , WA 98828

Revision 3 September 8, 2008W ENATCHEE W ORKS

R EVISED S EPTEMBER 8, 2008 

## T ABLE OF 

## C ONTENTS

PAGE

TABLE OF CONTENTS i

1.0 INTRODUCTION 1

2.0 START UP PLAN 2

3.0 SHUT DOWN PLAN 3

4.0 MALFUNCTION PLAN 4

LOW AIR FLOW

LOW ALUMINA FLOW

MAINTEN ANCE OF CONTINUOUS M ONTORING SYSTEM

LOSS OF POTLINE POWE R FOR AN EXTENDED PE RIOD

CATASTROPHIC FAILURE OF FUME CONTROL EQUI PMENT

VISIBLE EMISSION PLA NW ENATCHEE W ORKS PAGE 1

R EVISED J ANUARY 26, 2005

NOTE: All revisions to this plan are to be retained for five (5) years from their date of issue. 

### 1.0 INTRODUCTION

This Startup, Shutdown, Malfunction 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

1

– 3 and potline 5 at Wenatchee Works. This p lan will be made available to the permitting authority upon request. The startup, shutdown, and malfunction plan does not need to address any scenario that would not cause the source to exceed and applicable emission limitation in the

relevant standard (4 0 CFR Part 63.6(e)(3)).

If this plan is followed, the semi

- annual report will note that it was followed. Any action taken by the owner or operator during a startup or shutdown that caused the source to exceed any applicable emission limitation in the rel evant emission standards, or malfunction (including actions taken to correct a malfunction) is not consistent with the procedures specified in the affected source’s startup, shutdown, and malfunction plan, the owner or operator shall report the actions

tak en for that event within 2 working days after commencing actions inconsistent with the plan, followed by a letter within 7 working days after the event (40 CFR 63.10(d)(5)(2).

The semi

- annual report must note when the SSM Plan has been revised. Revisio ns 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.

Corrective actions fo r any SSM event must be initiated within 1 hour per 63.848(h).

Failure of a parameter to meet the parametric limit is an exceedance. The 7 th exceedance on a fume control device parametric in the semi

- annual reporting period will result in a violation. Both exceedances and violations must be reported on the semi

- annual reportW ENATCHEE W ORKS PAGE 2

R EVISED J ANUARY 26, 2005

NOTE: All revisions to this plan are to be retained for five (5) years from their date of issue. 

### 2.0 START UP PLAN

A start

- up or re

- start is defined as the process of re

- energizing an idled section(s) of aluminum reduction cells that is serviced by a common Fume Cont rol System(s) (device). The start

- up begins when the first idled reduction cell is energized. The start

- up concludes 180 days following

start

- up or after all pots have become stabilized, which ever occurs first. Stabilization parameters

are defined in the potroom operating control practice.

2.1 Potlines 1

- 3 with A

- 398 Control Systems and potline 5 with GTC Injector System

1

. The Operator is to assure that prior to adding liquid bath to the first pot, a fluidized bed of

alumina has been established in an A

- 398/GTC compartment. The Operator is responsible for starting alumina flow and airflow to the appropriate number of A

- 398/GTC compartments to ensure that the ratio of operating pots to operating A

- 398/GTC compartments does not exceed 18:1.

2

. In the event of a complete cold start up (i.e. no other pots operating at the site, the
operator may operate up to 6 pots without operating an A

- 398 / GTC compartment for no longer than 60 hours to entrain heat and facilitate the melting of bath in the first operationa l
pots.



### 3

. During start

- ups of potline portions, the operator is to assure that the ratio of pots operating to A

- 398/GTC compartments on line does not exceed 18:1. The operator is to also assure that operating parameters during the start

- ups of potline porti ons do not fall below the lower limits computed from the ratio of operating pots to the total pot count in the potline. The limits will be determined and compared using the calculations below on a daily basis:

Minimum Number of GTC Compartments =

18 Cells Operating of Number

⋅ ⋅ ⋅

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/GTC Compartments ).



### ( ) ( ) ( ) Line in Pots Total of Number Line in Pots Operating of Number Limit Parametric Potline

s value Parametric

⋅ ⋅ ⋅ ⋅ ⋅ ⋅ ⋅ ⋅ ⋅ ⋅ ×

⋅ ⋅

= ⋅ ) (

4

. The Sta rt

- Up is to be logged in the SSM Log

. 5

. Records of the start

- up are to be retained for five (5) years.W ENATCHEE W ORKS PAGE 3

R EVISED J ANUARY 26, 2005

NOTE: All revisions to this plan are to be retained for five (5) years from their date of issue. 

### 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 reductio n 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

co ncludes 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 total pot count in the potline. 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 pots in the potline. The limits will be determined and compared using the calculations below on a daily basis:

Number of Operating Fume Control Devices =

18 Cells Operating of Number

⋅ ⋅ ⋅

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 C ompartments ).



### ( ) ( ) ( ) Line in Pots Total of Number Line in Pots Operating of Number Limit Parametric Potline

s value Parametric

⋅ ⋅ ⋅ ⋅ ⋅ ⋅ ⋅ ⋅ ⋅ ⋅ ×

⋅ ⋅

= ⋅ ) (

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 compartments to be 18:1 or less for all potlines.

3.1 S hutdown Actions

1

. The Operator is to assure that throughout the shutdown, sufficient emission controls are kept operating such that a minimum ratio of 18:1 or less operating cells to control devices is maintained for all potlines.

2

. The Operator may shut dow n A

- 398/5W

- GTC 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 completing the SSM lo g.
4

. Records of the shutdown are to be retained for five (5) yearsW ENATCHEE W ORKS PAGE 4

R EVISED J ANUARY 26, 2005

NOTE: All revisions to this plan are to be retained for five (5) years from their date of issue. 

### 4.0 MALFUNCTION PLAN

4.1 Low Air Flow

Low airflow is defined as airflow conditions that generate a pot cycle (48hours) average CFM lower than the parametric limit. It is determine d by comparison of the average CFM for each fume control device over the potroom cycle to the established parametric . The parametric limit for a fraction of a potline running will be the normal parametric limit divided by the fraction of the potline

runni ng. .

Examples of low air flow conditions may include, but are not limited to, loss of electrical power, major bearing failure or unplanned compartment outages that result in simultaneous multiple compartment downtime within the control device.

4

. 1

. 1 Correc tive Actions :

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.

2

. The Operator is to confirm the system status, noting which component(s) are either off line or

ot herwise 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 completing the SSM log.

6

. Records are to be retained for five (5) years.

4.2 Low Alumina Flow

Low alumina flow is defined as alumina flow conditions that generate a pot cycle (48hours) total

alumina feed or rot ary vane feeder run time lower than the parametric limit. It is determined by comparing the fume control device rotary vane feeder total tons of alumina or run time in minutes during the potroom cycle to the limit. The parametric limit for a fraction of a potline running will be the normal parametric limit divided by the fraction of the potline running. Examples of activities or conditions contributing to low alumina flow conditions may include, but are not limited to; motor failure; motor control failu re; 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 unpl anned outages

.

4

. 2

. 1 Corrective Actions :

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 .

2

. The Operator is to confirm the system status, noting which component(s) a re 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 saf e, efficient, and timely manner.

5

. The Operator is responsible for completing the SSM log.

6

. Records are to be retained for five (5) years.W ENATCHEE W ORKS PAGE 5

R EVISED J ANUARY 26, 2005

NOTE: All revisions to this plan are to be retained for five (5) years from their date of issue. 4.3 Malfunction of Continuous Monitoring System

M alfunctions could include power interruptions, PLC/PC malfu nctions, and PLC

- PC communication problems.

4.3.1 Corrective Actions :

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

. 2

. The Operator is to confirm the system status, noting which 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 completing the SSM log.

6

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

years.

4.4 Loss o f Potline Power for an extended period A malfunction may cause the entire potline to be de

- energized for an extended period of time. In this situation, the fume control device may be shut down to conserve heat in the smelting cells.

Under this situation , DC power to the pots is lost but AC power to the reactors is available. ,It may be decided very early on after DC power is lost (i.e. within an hour) to shutdown the control device to conserve heat. This is justified under the general duty clause since keeping the potline running even under this scenario would cause less emissions than allowing the potline to run cold, then going through a long cold restart process. The latter may take up to 180 days before the potline returns to stable operations.

4.4.1 Corrective Actions:

1

. Following the request to idle the fume control device, the Operator will stop the fans and alumina flow for the reactor compartments.

2

. The Operator is responsible to begin startup of reactor compartments in a safe, efficient, a nd timely manner following the re

- energization of the potline.



### 3

. Normal operation is to be attained as soon as possible following the SOPs for startup of the

compartments



### . 4

. The Operator is responsible for completing the SSM log.



### 5

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

.

4.5 Catastrophic Failure of Fume Control Equipment

A catastrophic failure of the fume control equipment is considered a malfunction. Examples of catastrophic failure may include, but are not limited to; collaps e of a unit inlet duct, a direct lightning strike, a loss of electrical power, an earthquake, a tornado, or a system fire that results in

uncontrolled emissions.

4.5.1 Corrective Actions :W ENATCHEE W ORKS PAGE 6

R EVISED J ANUARY 26, 2005

NOTE: All revisions to this plan are to be retained for five (5) years from their date of issue. 1

. The operator is to log the time that the condition was first noti ced 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

li ne 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 t imely manner.

5

. The Operator is responsible for completing the SSM log.

6

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

4.6 Visible Emissions

Typical visible emissions are defined as the presence of visible emissions indicative of abnor mal fume control device operation during the required daily visible emissions check

.

4.6.1 Corrective Actions :

1

. The Operator is to report the dusting stack(s) from MACT sources during the daily visual checks made by the Operator.

2

. The Operator is to l og 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 completing 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

. Records of the v isible emissions are to be retained for five (5) years.

Revisions:

Revision Date Description Initials

Rev. 0 09

- 09

- 99 Original HMV

Rev. 1 07

- 05

- 00 Revised to include Potline 3 HMV

Rev. 2 01

- 26

- 05 Revised to include better description of startup,

shut down procedures RJL

Rev. 3 09

- 08

- 08 Revised to incorporate changes in SSM requirements KAK