# A

Alcoa Inc

Intalco Works

National Emission Standards for Hazardous Air Pollutants for Primary Aluminum Reduction

Plants



# Anode Bake Oven

Startup, Shutdown, and Malfunction Plan

Issued: Oct. 8, 1999

Current Rev. Date : July 15

, 2005Alcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: i of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc 

### Table o f Contents

Introduction

................................ ................................ ................................ ................... 1

SSM Plan Requirements

................................ ................................ ............................. 2

Start

- Up/Re

- Start B aking Furnaces

................................ ................................ ............. 4

Shut

- Down of Baking Furnaces

................................ ................................ ................... 5

Malfunction and Corrective Action Plans

................................ ................................ ... 7

Malfunction and Corrective Action Plan Procedure Documentation

............................ 7

High Flow of Process Gas

................................ ................................ ........................... 8

Visible Em issions

- Dusting Stack(s)

................................ ................................ ......... 10

Loss of Parametric Monitoring Signals

................................ ................................ ...... 11

Catastrophic Failure of Emission Control Equipment

................................ ................ 12

Revision Summary

................................ ................................ ................................ ...... 13

Appendices

................................ ................................ ................................ .................. 14

Startup, Shutdown, Malfunction / Operating Limit Exceedance Report: Potlines and

Bake Ovens

................................ ................................ ................................ ................. a

PMACT Event Flow Chart

................................ ................................ ............................ bAlcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 1 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc Introduction

This document represents the Startup, Shutdown, and Ma lfunction Plan (SSMP) for the Alcoa Intalco Works Primary Aluminum Smelter’s Anode Bake Oven as required under Title 40 CFR 63.6(e).

40 CFR § 63.6(e) requires that Intalco develop a Startup, Shutdown, and Malfunction

Plan that describes the procedures to f ollow, and corrective actions to take, during

events when the Anode Bake Oven , associated emission control equipment, or monitoring equipment experience a start

- up, shutdown, or malfunction. The term

“ malfunction ” is defined at 40 CFR §63.2 as “any sudden , infrequent, and not reasonably preventable failure of air pollution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions .”

The purpose of the startup, shutdo wn, and malfunction plan is to:

• Ensure that, at all times, the owner or operator operates and maintains each affected source, including associated air pollution control and monitoring equipment,

in a manner which satisf ies the general duty to minimize emissions established by

para graph (e)( 1)(i) of 40 CFR Part 63‚ Section 6

.

• Ensure that owners or operators are prepared to correct malfunctions as soon as practicable after their occurrence in order to minimize excess emiss ions of hazardous air pollutants; and

• Reduce the reporting burden associated with periods of startup, shutdown, and malfunction (including corrective action taken to restore malfunctioning process and air pollution control equipment to its normal or usual manner of operation).

Notes regarding document control:

• The plan will be made available to the permitting authority upon request.

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

• The Environmental Department Ma nager must approve any changes to this SSM plan.

The Corrective Action Plans described in this document must be initiated within one hour of first becoming aware that a parametric value was not achieved. Each parametric

exceedance in excess of the six all owed during a semiannual reporting period is a

violation.Alcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 2 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc **SSM Plan Requirements**

The following is a **summary** of this SSM plan’s requirements, as required by federal regulations. It is important that each individual be familiar with the requirements to

ensu re the SSM program’s success.

1

. Keep records of each SSM event as required and report if an action taken during an SSM event is not consistent with the procedures in the SSM plan.

2

. Maintain all SSM records for at least five years (2 of which must be onsite).

3

. Maintain records documenting the occurrence and duration of each startup, shutdown, or malfunction (refer to this plan for details).

4

. Document maintenance performed on the air pollution control equipment.

5

. Document actions taken during periods of SSM, incl uding corrective actions to restore air pollution control equipment to normal operating conditions.

6

. Notify the Environmental Department as soon as possible after taking any actions that deviate from the SSM plan. On day shift, notify the Environmental D epartment immediately; during the night shift, notify the Environmental Department on the following working day. Include an explanation of the event:

− The exact timing of the event

− The name of the person who decided not to follow SSM requirements

− Reasons fo r not following the SSM plan

− Whether parametric monitoring exceedances occurred during the event

7

. Maintain documentation necessary to show conformance with the SSM plan during

an SSM event.

8

. Maintain documentation of each period of continuous monitoring syst em (CMS) malfunction or inoperative periods (including out of control periods, calibration periods, downtime, etc.).

9

. Document all required measurements to demonstrate compliance with a relevant standard, including but not limited to all 24 hr average readi ngs of CMS data.

10

. Maintain documentation of all results of performance tests, CMS performance
evaluations, and visible emission observations.

11

. Document all CMS calibration checks performed

. 12

. Document all adjustments and maintenance on CMS, including routine maintenance performed.

13

. Submit summary report, including relevant data from production and maintenance, by the 7 th day of each quarter to the Environmental Department for preparation of quarterly reports. Keep all SSM plan

- required data in the Emission Con trol Supervisor’s office

— send only copies or relevant reports and/or summaries to the Environmental Department.Alcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 3 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc 14

. Notify the Environmental Department as soon as possible if the SSM plan fails to address or inadequately addresses an event that meets the chara cteristics of a malfunction but is not included in the SSM plan. The Environmental Department will revise the plan within 45 days to address the issues.

− If this occurs on day shift, notify the Environmental Department immediately.

− If this occurs during t he night shift, notify the Environmental Department on the following working day.

15

. Document dates and times the CMS is out of control or inoperative:

− Specific periods of excess emissions and parametric exceedances (start and end times) during SSM events, and otherwise if applicable

− The nature and cause of any exceedance

− Corrective actions taken

− Preventative measures taken

− Adjustments made to the measurement instrument, total process operating time, or paste plant control equipmentAlcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 4 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc Start

- Up/Re

- Start Baking Furnaces

In the event that a start

- up or re

- start 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 the following Start

Up plan 

### must be initiated within one hour of first becoming aware of the situation.

A start

- up or re

- start is defined as the process of initiating heating to an Anode Baking furnace in which all sections of that furnace(s) have previo usly been at ambient
temperature

. 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).

1 ) The Operator(s) is to assure that prior to start

- up or re

- st art that fresh ore flow (alumina) and air flow has be en established in the Bake Oven Control Device (Baghouse 7) , and that the parametric limits stated in this plan are being met

. 2 ) The start

- up or re

- start concludes when fire(s) begin to move

3 ) Records of the start

- up are to be retained for five (5) years. Should an exceedance
occur, it is to be entered into the semi

- annual reporting period log kept by the Environmental Department and be reported in the monthly air operating report

submitted for the month in question

.Alcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 5 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc Shut

- Down of Baking Furnaces

In the event that a shut

- down of a baking furnace(s) creates or leads to a situation that causes operation outside of appropriate parametric ranges for process gas flow or
alumina flow the following Shut

- Down p lan 

### must be initiated within one hour of first becoming aware of the situation. Two types of furnace shutdown conditions could occur

on site and both are addressed below:

Long Term

A long term shutdown is defined as the process of allowing a complete ano de baking furnace(s) to cool to ambient temperature. The shutdown 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 shutdown concludes 72 hour s after use of heating fuel has been discontinued.

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

ceased and the control device (Baghouse 7) may be shut down

. 2 ) Records of the shut

- down are to be retained for five (5) years. Should an

exceedance occur, it is to be entered into the semi

- annual reporting period log kept by the Environmental Department and be reported in the monthly air operating report submitted for the month in question

.

Short Term

A short term shutdow n is utilized when short term routine maintenance, repair, and/or replacement activities to the system are required to ensure continued safe and proper operation of bake furnace and associated emission control equipment. These types of

routine maintenance , repair, and/or replacement activities are typically completed in

less than one shift and can not be safely completed without a shut down of the emission control system.

In order to minimize emissions during the above mentioned routine maintenance, rep air, and/or replacement activities the facility will perform the following steps:

1

. All natural gas (fuel) to the anode baking furnaces will be shut off prior to any work being performed:

2

. All emission control systems will continue to operate following shut down of natural gas for a minimum of three hours to allow for purging of the ductwork and continued emission control during the three hour period.Alcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 6 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc 3

. Following that purge/cool down period bake furnace operating personnel will

shutdown the emission control system and begin the required routine maintenance, repair, and/or replacement activities needed to ensure safe and proper operation of the entire system.

4

. All such work performed in 3. above will be performed in an expedited

manner and the emission contro l system will be re

- started as soon as possible following repairs.

5

. All work performed will be documented and r ecords of the shut

- down are to be retained for five (5) years. Should an exceedance occur, it is to be

entered into the semi

- annual reportin g period log kept by the Environmental Department and be reported in the monthly air operating report submitted for the month in question.Alcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 7 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc Malfunction and Corrective Action Plans

This section describes scrubber malfunctions and corrective action to take in the event of a malfunction, including the following malfunction scenarios:

• High Air Flow (Process Gas)

• L oss of Alumina Feed

• Visible Emissions

- Dusting Stack(s)

• Loss of Parametric Monitoring Signals

• Catastrophic Failure of Emission Control Equipment

In the event of a malfunction, the applicable malfunction plan must be initiated within one hour of the malfunction being detected. The procedures in this section describe the steps to take to determine the cause, remedy the problem, and document the event.

**Malfunction and Corrective Action Plan Procedure Documentation**

Records to verify conformance with the scrubber malfunction procedures are:

• SSM Exceedance Report

• Emission Control System Continuous Parameter Monitoring RecordsAlcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 8 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc **High Flow of Process Gas**

In the unlikely event of high flow of process gas (a.k.a.

- high air flow) through this fume
control system (device) the following malfunction and corrective action plan 

### must be initiated within one hour of first becoming aware of a malfunction.

High gas flo w rates will reduce gas residence time in the dry alumina scrubber and may therefore have a slight impact on POM removal efficiency, but the gas flow rate is already limited by fan capacity. Examples of this would be a condition that impacts the

control d evice so that an annubar flowmeter parametric is generated above the acceptable limits (see table 4.2 below).

Table 4.2

. Bake Oven Operating Limits

Monitored

Parameter Type of

Limit Operating Limit

Air Flow High 116,000 scfm

Ore Flow Low 5 Hours with No

Fresh Ore Flow

1 ) The operator is to confirm the system status. 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 thi s initial response, the operator or proxy is to notify appropriate maintenance personnel and/or initiate a maintenance work order, or restart the unit 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 logging the duration of the malfunction and the cause. Maintenance personnel will be responsible for making appropriate entries into any maintenance logs.

5 ) Records of the start

- up are to be retained for five (5) years. Should an exceedance
occur, it is to be entered into the semi

- annual reporting period log kept by the Environmental Department and be reported in the monthly air operating report submitted for the month in question.Alcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 9 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc Loss of Alumina Feed

In the event of loss of alumina through this fume control system (device) the following
malfunction and corrective action plan 

### must be initiated within o ne hour of first becoming aware of a malfunction.

Examples of low flow conditions include, but are not limited to; unexpected failure to provide fresh alumina throu gh the fresh alumina feed duct or one of its components and

reductions in alumina flow due to unplanned Control Device (Baghouse 7) compartment outages that result in simultaneous multiple compartment downtime within this control device that generates loss of fresh alumina parametric that is below acceptable limits (see table 4.2 Ore Flow)

.



### Tab le 4.2

. Bake Oven Operating Limits

Monitored

Parameter Type of

Limit Operating Limit

Air Flow High 116,000 scfm

Ore Flow Low 5 Hours with No

Fresh Ore Flow

1 ) The operator is to confirm the system status, noting which Control Device (Baghouse 7) c ompartments are in a no feed or reduced feed 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 respon se, 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

re placement(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 logging the duration of the malfunction and the cause. Maintenance personnel will be responsible for making

appr opriate entries into any maintenance logs.

5 ) Records of the start

- up are to be retained for five (5) years. Should an exceedance
occur, it is to be entered into the semi

- annual reporting period log kept by the Environmental Department and be reported in the monthly air operating report submitted for the month in question.Alcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 10 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc **Visible Emissions**

**- Dusting Stack(s)** 

In the event of visible emissions, dusting stack(s), for this anode bake oven control
device (Baghouse 7). The following malfunction and corrective a ction plan 

### must be initiated within one hour of first becoming aware of a malfunction.

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 anode bake

o ven control device (Baghouse 7).

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 made confirmation of the report.

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 logging the event in the visible emission log. Maintenance personnel will be responsible for making appropriate entries into any maintenance logs.

5 ) Records of the start

- up are to be retained for five (5) years. Should an exceedance
occur, it is to be entered into the semi

- annual reporting period log kept by the Environmental Department and be reported in the monthly air operating report submitted for the month in question.Alcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 11 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc **Loss of Parametric Monitoring Signals**

In the event of loss of fresh alumina feed, or air flow

, signal(s) for this Anode Bake Oven
Control system (device) the following malfunction and corrective action plan 

### must be initiated within one hour of first becoming aware of a malfunction.

Examples of a loss of signal include, but are not limited to; unexpected failure of the programmable logic controller, PLC, or loss of an annubar flowmeter device that monitors the airflow parametric.

1 ) The operator is to confirm the system status, noting if the PLC is off line or which Control Device (Baghouse 7) compartments have suffered signal loss. The operator is to log the time that the condition was first notice d 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 restar t 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 logging the duration of the malfunction and the cause. Maintenance personnel will be responsible for making appropriate entries into any maintenance logs.

5 ) Records of the start

- up are to be retained for five (5) years. Should an exceedanc e occur, it is to be entered into the semi

- annual reporting period log kept by the Environmental Department and be reported in the monthly air operating report submitted for the month in question.Alcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 12 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc **Catastrophic Failure of Emission Control Equipment**

In the event of catastrophic failure of emission control equipment or components in this
fume control system (device) the following malfunction and corrective action plan 

### must be initiated within one hour of first becoming aware of a malfunction.

Examples of catastrophic failure include, but are not limited to; collapse of a control device (Baghouse 7) 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 stab le and hazards have been cleared, the operator or proxy is to confirm the system status, noting which Control Device (Baghouse 7) 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 to check the system status.

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 capacit y. Such decisions may initiate appropriate Shut Down plans.

4 ) The system operator or proxy will be responsible for logging the duration of the malfunction. Maintenance personnel will be responsible for making appropriate entries into any maintenance logs.

5 ) Records of the start

- up are to be retained for five (5) years. Should an exceedance
occur, it is to be entered into the semi

- annual reporting period log kept by the Environmental Department and be reported in the monthly air operating report

submitted for the month in question.Alcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 13 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc Revision Summary

Note: 40 CFR Part 63‚ Section 850‚ Paragraph (c) states that Ecology may review this plan upon request. Approval must be obtained by Ecology before any significant changes implemented. 40 CFR 63.6(e)(3)(viii) requi res all changes be reported in Semi

- annual Excess Emissions Report.

Revision

Date Nature of Revision Document Review Participants

Oct. 8, 1999 Rev. 0: Original Issuance D. Ringwald

June 1, 2005 REV 1

Previous SSM Plan was se parated into

two documents: SSM Plan Potlines and

this SSM Plan for Anode Bake Ovens. No parametric content changed. The following formatting, editing, and

clarifications were made:

• Deleted reference to lower air flow parametrics referenced in Start Up

and Shut Down which were not

ap plicable given the high air flow rate

limit.

• Added Controlled Document

Elements.

• Added Example “ Sample Start up, Shut down, Malfunction Exceedance Report”

• Revised PMACT Event Flowchart to clarify Emission Control’s responsibilities versus Environmental

De partment.

• Revised Introduction.

• Transferred all Potline information to a

new “ Potlines Startup, Shutdown, and

Malfunction Plan.

• Added Summary of SSM Plan Requirements. Jim Schon, Dave Ringwald, Brad Oxford, Kathryn Mitchell (Anvil)

(Reported to Ecology i n 2005 First Semi Annual Excess Emissions Report).

July 15, 2005 REV 2

Added “Short Term” shut down condition to “Shut Down of Baking Furnace” Section on page 5 of 13

. • Department of Ecology July 13,

2005 email from Judy Schwieters to

Jim Schon

.

• Jim Schon , Mike Rousseau, Barry
Hullett, Patrick Pollock; Roger
Nordlund, David Ringwald, Kathryn Mitchell, Bradford Oxford, Matt Loya; Larry Bouma; Ray Chapman; Charles Knauft, Iv, Ron MannAlcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 2

Rev. Date: 0 7.15 .05 Page: 14 of 13

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc Appendices

Sample S tart up, S hut down, M alfunction Exceedance Report

PM ACT Event Flow ChartAlcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 1

Rev. Dat e: 06.01.05 Page: a of Appendix

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc 

### Startup, Shutdown, Malfunction / Operating Limit Exceedance Report:

**Potlines and Bake Ovens**

Control Device:

_______________________

Date/Time of SSM Event / Exceedance was detected:

Describe Cause of SSM Event / Excee dance (if known):

Time Corrective Action Started:

Describe Corrective Action:

Was the SSM Plan Followed? (Circle one): 

### Yes / No

Reported by:

(Name) (Badge #) This form is to be forwarded to your supervisor as s oon as practicable. An email alert to your supervisor is also requested Air Flow

Fresh Ore Flow

Water Flow

Abnormal Visible Emission

Loss of Parametric Monitoring Signals

Catastrophic Failure of Emission C ontrol Equipment

Cold Weather ShutdownAlcoa Intalco Works Anode Bake Oven Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon

Issue Date: 10.8.99

Rev. No.: 1

Rev. Dat e: 06.01.05 Page: b of Appendix

Controlled Document

Controlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc **PMACT Event Flow Chart**

Notify

Environmental Staff Day shift

, notify immediately Night shift

, notify on the following working day

.

Make

Internal / External

Notifications

Submit

Internal / External Reports

Archive Reports and Documentation

for

5 years Yes SSMP

Event

VIOLATION

SSM

Procedures

initiated within

1 hour ?

Yes

Yes No

SSM Plans

Followed ? VIOLATION No YesControlled documents are maintained electronically as described in Document Control. Printed versions of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

4:25 PM ssmp_Bakes_current.doc End of SSM

O: \ InfoShare \ Controlled_Documents \ Environmental \ E

- 3 Air \ Programs \ PMACT \ Startup

Shutdown Malfunction Plans \ ssmp_Bak es_current.doc