# A

Alcoa Inc

Intalco Works

National Emission Standards for Hazardous Air Pollutants for Primary Aluminum Reduction

Plants



# Green Mill

Startup, Shutdown, and Malfunction Plan

August 18 , 2005Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: i of 23

Controlled Document

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

4:25 PM 

### Table of Contents

Introduction

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

SSM Plan Requirements

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

Process Description

................................ ................................ ................................ ..... 3

Anode Production System Startup

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

Startup Procedure

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

Anode Production Startup Procedure Documentation

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

Anode Production Process Shutdown

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

Normal Shutdown

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

Abnorma l Shutdown

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

Anode Production Shutdown Procedure

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

Anode Production Shutdown Procedure Documentation

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

Malfunction and Corrective Action Plans

................................ ................................ ... 9

Malfunction and Corrective Action Plan Procedure Documentation

............................ 9

Low Air Flow

................................ ................................ ................................ ................ 9

Low Coke Flow

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

Abnormal Visible Emissions

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

Continuous Parameter Monitoring System (CPMS) Malfunction

............................... 15

Catastrophic Failure of Process or Emission Control Equipment

.............................. 17

Revision Summary

................................ ................................ ................................ ...... 19

Appendices

................................ ................................ ................................ .................. 20

Sample SSM Incident Form

................................ ................................ ....................... 20

PMACT Event Flow Chart

................................ ................................ .......................... 20Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 1 of 23

Controlled Document

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

4:25 PM Introduction

Alcoa Intalco Works operates a Green Mill to produce carbon anodes for aluminum

reduction cells . 40 CFR § 63.850(c) requires that a plan be developed that describes the procedures to follow, and corrective actions to take, during events when green mill equipment, 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.”

This Startup, Shutdown, Malfunction (SSM) Plan has been prepared to fulfill the requirements of 40 CFR §63.850(c), and contains procedures to be used during periods of Green Mill and Pitch Fume Treatment System startup, shutdown, and m alfunction. The plan also identifies the actions to be taken during green mill emission control equipment, or monitoring equipment SSM events.

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 Manager must approve any changes to this SSM plan.

Table 1 describes the monitoring frequencies, record keeping requirements, and lower parametric limits for the Green Mill’s air emission control equipment, also referred to as “the Pitch Fume Treatment System” or “dry coke scrubber.” As summarized in the Table 1, a parametric exceedance occurs when airflow is below 46 ,000 acfm and/or coke flow is below 4,500 lb/hr, based on a 24 hr average of 5 minute averaged data. Data is collected and averaged during hours of green mill operation. 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 allowed during a semiannual reporting period is a violation.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 2 of 23

Controlled Document

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

4:25 PM Table 1: Monitoring frequency, record keeping requirements, and lower parametric limits.

Paramete r Measurement Measurement
Frequency Record Data
Frequency Archive Data
Frequency Data used to

indicate Compliance Lower

Limit

Coke flow from

main feed tank

SI

- 500 Rotary feeder valve (RAL 510) RPM Continuous during green mill operation 5 minute block

aver ages of 1

second readings Hourly average

values a 24 hr average

of 5 minute

block

averages b 6.25 RPM
(RPM at 4,500 lb/hr)

Air flow Annubar
(EQ #: FE/FT

0800) Continuous
during green mill operation 5 minute block averages of 1

second readings Hourly aver age
values a 24 hr average

of 5 minute

block

averages b 46 ,000 acfm

a Hourly average values to be kept on

- site 2 years and off

- site at least 3 years.

b 24 hours defined as from 6 AM

– 6 AM.

**SSM Plan Requirements**

The following is a **summary** of this SSM plan’s r equirements, as required by federal regulations. It is important that each individual be familiar with the requirements to ensure 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 no t 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 deta ils).

4

. Document maintenance performed on the air pollution control equipment.

5

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

6

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

− The exact timing of the event

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

− Reasons for 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 system (CMS) malfunction or inoperative periods (including out of control periods, calibration periods, downtime, etc.).Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 3 of 23

Controlled Document

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

4:25 PM 9

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

10

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

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 qua rter to the Environmental Department for preparation of quarterly reports. Keep all SSM plan

- required data in the Emission Control Supervisor’s office

— send only copies or relevant reports and/or summaries to the Environmental Department.

14

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

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

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

15

. Document dates and times the CMS is out of co ntrol 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

− Adjustmen ts made to the measurement instrument, total process operating time, or paste plant control equipment

**Process Description**

Anode production involves mixing calcined petroleum coke and anode scrap materials with coal tar pitch and forming these materials int o anode blocks. Metered amounts of coke, scrap, and pitch are blended in continuous mixers. The paste is then conveyed to anode forming equipment, which compresses the paste material into an anode.

The process control system for the anode production proce ss is based on the SQD and AllenBradley programmable logic controllers (PLC). The control sequence is written in standard ladder logic language. The process is displayed using a Human Machine Interface (HMI). The operator uses the HMI to control the proc ess.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 4 of 23

Controlled Document

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

4:25 PM Pitch fumes are generated during both mixing and forming operations. The emission control system, or dry coke scrubber, is designed and operated to adsorb pitch fumes onto coke fines. The coke fines are injected into a Venturi

- type contact column an d into the ductwork near the fume collection hoods where they come in contact with the pitch fumes. The coke fines adsorb the pitch fumes and become enriched. A baghouse captures the enriched coke together with the pollutants present in solid form or drop lets. Enriched coke collected in the baghouse is recycled back into the anode production

process.

Anode Production System Startup

To prevent excess or uncontrolled emissions from the Green Mill, this startup plan must be followed for all startups.

Start

- up Definition:

• T he process of turning on the emission control equipment and the pitch pumps that inject liquid pitch into the mixers.

• Begins when the emission control system is started.

• Concludes when the pitch pumps inject liquid pitch into the mixers.

Appropriate limits for parametric ranges during startup are:

• Airflow: 46 ,000 acfm

• Coke flow: 4,500 lbs/hr

Typically, the paste production plant’s routine startup occurs once per day, depending on production schedules. In addition, startup occurs after intentional shutdown for scheduled maintenance or meetings. Startup events also occur when the system is restarted after a shutdown caused by a malfunction.

The paste production process is started through a request from the PLC in the Green

Mill control room. Before the paste mixing system is activated, a n electrical signal

which indicates that both the dry coke scrubber fan and RAL 510 (coke feeder) are operating must be present. If the signal is not present, activation of the paste mixing
system will not be allowed

. The PLC sequences the start of different components (i.e., mixers, screw conveyors, etc.) while checking for interlocks to avoid clogging. An automatically

- controlled conveying sequence handles the different components’ start sequencing and timing. Upstream units start only after downstream units have been brought on

- line.

The dry coke scrubbing system must always be started and fully operational before starting the anode production process. There are no excess emissions during a nor mal
startup.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 5 of 23

Controlled Document

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

4:25 PM An Abnormal Start up is defined as operation of the emission control equipment outside acceptable parametric limit during a start up.

**Startup Procedure**

To minimize emissions during startup, the operator (or proxy) is to:

1

. Initiate startup of the dry coke scrubber by pressing the sequence start on the HMI.

2

. Verify that airflow is above the parametric limit (not less than 46 ,000 acfm).

3

. Verify that coke flow is above the parametric limit (not less than 4,500 lb/hr).

4

. Troubleshoot any system faults or alarms.

5

. Initiate mixing and forming process for A and/or B lines.

In the event of an abnormal startup (operation outside of acceptable parametric limit during a start up), the operator (or proxy) is to initiate the following procedures within

one hour of first becoming aware of the situation :

6

. Assure that the emission control system is still on line.

7

. If not on line, initiate the shut down green anode mixing, green mix transfer, and green anode forming equipment.

8

. Describe the abnormal startup on the SSM Incident Form (see attachments) . Include the following information:

− Date

− Name of person(s) completing form

− Description of malfunction

− Time of malfunction detection

− Time corrective action plan was initiated

− Details of actions taken.

− Time correct ive action complete

− Whether this Startup, Shutdown, an d Malfunction Plan was followed (yes or no)

**Anode Production Startup Procedure Documentation**

The occurrence of each startup is electronically recorded.

The duration of a normal startup is specified as 15 minutes in Intalco’s Safety and Standard Operating Procedure (SSOP) “Pitch Fume Treatment System Operation.” Compliance with Intalco’s SSOP program is used as duration documentation.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 6 of 23

Controlled Document

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

4:25 PM In the unlikely event that startup is abnormal (e.g. pitch pump is turned on before air pollution control equipment) an SSM Event Form will be completed.

Startup records are kept for five (5) years.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 7 of 23

Controlled Document

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

4:25 PM Anode Production Process Shutdown

To prevent excess or uncontrolled emissions from the Green Mill, this shutdown plan

must be fol lowed for all shutdowns. In the event that a shut

- down of green anode processing equipment served by the dry coke scrubber system creates or leads to a situation that causes control device operating parameter outside of appropriate parametric ranges, the a ppropriate malfunction plan must be initiated within one hour of first becoming aware of the situation.

**Normal Shutdown**

Shutdown Definition:

• The process of intentional shutdown of green anode mixing, mix transfer, and green

anode

- forming equipment and emi ssion control equipment.

• Shutdown begins when pitch flow to the mixer is stopped, ending the ongoing production of green anode paste.

• Shutdown c oncludes when all the paste has been processed (the mixers and belts no longer have paste in them or on them ) and the emission control system is shut

down.

• Shutdown r equires a minimum of 15 minutes between stopping the pitch flow and shutting down the emission control system.

Note: If the process equipment is shut down for parts of the day while the air emiss ion control equipment is operating, the system does not meet the definition of a shutdown

condition.

Typically, the paste production plant’s routine shutdown occurs once per day, depending on production schedules. In addition, shutdown occurs for schedul ed maintenance or meetings. The occurrence and duration of each shutdown is electronically recorded.

**Abnormal Shutdown**

Abnormal Shutdown Definition:

• Any shutdown which is not consistent with the definition of shutdown above

• Any shutdown that occurs as a result of a PFTS malfunction.

Abnormal shutdowns will be documented using an SSM Event Form, which will document that the SSM plan was followed.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 8 of 23

Controlled Document

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

4:25 PM The paste production process is shut down through a request from the PLC in the

Green Mill control room. Pr ior to shutdown all mixers will be discharged. The dry coke scrubbing system will not be shut down until this has occurred.

There are no excess emissions during a normal shutdown of the paste production process. Operating the dry coke scrubber until af ter all paste production systems (e.g., mixers) are shut down minimizes emissions.

**Anode Production Shutdown Procedure**

To minimize emissions during shutdown the operator (or proxy) is to:

1

. Verify that all mixers have been discharged.

2

. After the system compon ents have cooled, initiate shutdown of dry coke scrubber.

In the unlikely event that a shutdown of green anode processing equipment served by the dry coke scrubber leads to a situation that causes operation outside of appropriate parametric ranges for pr ocess gas flow or coke flow, the following plan must be initiated within one hour of first becoming aware of the situation:

3

. Describe the abnormal shutdown on the SSM Incident Form. Include the following

information:

− Date

− Names of persons completing form

− D escription of malfunction

− Time of malfunction detection

− Time corrective action plan was initiated

− Details of actions taken.

− Time corrective action complete.

− Whether this Startup, Shutdown, and Malfunction Plan was followed. (yes or no)

**Anode Production Shu tdown Procedure Documentation** 

The occurrence and duration of each shutdown is electronically recorded.

In the event that a shutdown is abnormal (e.g. air pollution control equipment is turned off before the pitch pumps) an SSM Event Form will be complet ed.

Shutdown records are kept for five (5) years.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 9 of 23

Controlled Document

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

4:25 PM 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:

• Low air f low

• Low coke flow

• Visible emissions

• Continuous Parameter Monitoring System (CPMS) Malfunction

• Catastrophic Failure of Process or Emission Control System

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 wit h the scrubber malfunction procedures are:

• SSM Incident Form

• Emission Control System Continuous Parameter Monitoring Records

**Low Air Flow**

Low airflow is defined as airflow lower than the established lower parametric limit of

46 ,000 acfm as defined in table 1

.

The parametric airflow is measured at the exhaust stack. The airflow is displayed on

the HMI Control Screen in the Green Mill control room

. A Low Air Flow Alarm is displayed on the PLC Control Screen if airflow drops 500 acfm below 46 ,000 acfm as a leading indicator system to allow avoid an exceedance.

The following Corrective Action Plan must be initiated within one hour of first becoming aware that the low flow parametric value was not achieved

.

During the initial response, the operator is t o:

1

. Confirm the system status.

2

. Log the time that he/she first became aware of the low air flow condition

3

. Log time at which he/she initiated this corrective action plan (must be within one hour).

4

. Notify appropriate personnel such as the Paste Plant Superv isor, Maintenance Plant Supervisor, maintenance personnel and/or restart the components.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 10 of 23

Controlled Document

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

4:25 PM After the initial response, the operator and/or maintenance personnel are to:

5

. Troubleshoot the system.

6

. If appropriate, use the guidance on Table 2, below, to determi ne the malfunction’s

cause.

7

. Make necessary repairs, equipment replacement, or process changes to remedy the situation in a safe, efficient, and timely manner.

8

. Verify that the airflow has returned to a level above the low airflow limit (54,000 acfm).

9

. If t he action taken to remedy the situation fails to correct the problem, shut down the anode production process. Restart the process only after repairs, equipment replacement, or process changes have been completed and all malfunctions are

corrected.

10

. Describe the malfunction on the SSM Incident Form. Include the following

information:

− Date

− Name of person(s) completing form

− Description of malfunction

− Time of malfunction detection

− Time corrective action plan was initiated

− Details of actions taken.

− Time correctiv e action complete.

− Whether this Startup, Shutdown, and Malfunction Plan was followed. (yes or no)

11

. Submit the form to the Green Mill Production Supervisor. The Green Mill Production Supervisor will

− Complete the SSM Incident Form,

− File in the Green Mill Pr oduction Supervisor’s office, and

− Notify plant Environmental staff.

12

. Maintenance personnel are responsible for making appropriate entries into any maintenance logs.

13

. Retain records of each SSM event for five (5) years.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 11 of 23

Controlled Document

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

4:25 PM Table 2: Dry Scrubber low airflow tro ubleshooting

Possible Causes Corrective Actions Check exhaust fan for proper operation. Initiate process to repair the exhaust

fan.

Verify main fan damper in the exhaust stack is closed so that air is not being recirculated into the baghouse. Adjust d amper as necessary to restore adequate airflow. If necessary, initiate process to repair the damper.

Verify that baghouse resistance is within normal pressure range. Differential pressure across baghouse should be below 7 inches

H 2 O. Maintain adequate pul se air pressure by restoring compressed air system or bypassing to the main plant air
system.

If main exhaust fan, damper, and baghouse are operating properly, check exhaust airflow monitoring device for proper operation. Initiate process to repair monito ring device if necessary.

**Low Coke Flow**

Low Coke Flow is defined as a coke flow rate lower than the parametric limit of 6.25 RPM ( 4,500 lb/hr ) as defined in Table 1

.

A lower limit for coke flow is established to ensure optimal polycyclic organic matter (POM) capture efficiency. A higher limit is irrelevant for air pollution control purposes. High flow rates are undesirable for long

- term operation and fire safety because condensed coal tar pitch deposits could build up inside the ductwork.

Coke flow is controlled by a rotary vane feeder (RAL 510) from the 25

- ton injected fines coke feed tank to the primary scrubber. The feeder drive motor

- starter contacts determine the vane feeder rotation. The motor rpm and the rotary vane feeder displacement capaci ty determine the coke flow. The accuracy of the calculated coke flow rate depends primarily on variations in the bulk density of dry coke, which typically varies +5% across 6 standard deviations (3 standard deviations on each side).

In addition, a flow

- sensing device downstream of the rotary vane feeder indicates to the operator that coke fines are being injected into the primary control device.

Examples of low flow conditions include, but are not limited to, an unexpected failure of the primary coke feeder or one of its components that causes an hourly average rotaryAlcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 12 of 23

Controlled Document

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

4:25 PM vane feeder

- RPM measurement that is below the rotary vane feeder

- RPM parametric

limit.

In the event of low flow of coke to or through the emission control system, the following

malfuncti on and corrective action plan must be initiated within one hour of first becoming aware of a malfunction.

During the initial response, the operator (or proxy) is to:

1

. Confirm the system status.

2

. Log the time that he/she first became aware of the low air flow condition

3

. Log time at which he/she initiated this corrective action plan (must be within one hour).

4

. Notify appropriate personnel such as the Paste Plant Supervisor, Maintenance Plant Supervisor, maintenance personnel and/or restart the components.

After the initial response, the operator (or proxy ) and/or maintenance personnel are to:

5

. Troubleshoot the system.

6

. If appropriate, use the guidance on Table 3, below, to determine the malfunction’s

cause.

7

. Make necessary repairs, equipment replacement, or process changes to remedy the situation in a safe, efficient, and timely manner.

8

. Verify that the coke flow has returned to a level above the low coke flow limit (4,500 lbs/hr).

9

. If the action taken to remedy the situation fails to correct the problem, shut down the anode production process. Restart the process only after repairs, equipment replacement, or process changes have been completed and all malfunctions are

corrected.

10

. Describe the malfunction on the SSM Incident Form. Include the following

informati on:

− Date

− Name of person(s) completing form

− Description of malfunction

− Time of malfunction detection

− Time corrective action plan was initiated

− Details of actions taken.

− Time corrective action complete.

− Whether this Start up, Shut down, and Malfunction Plan was followed. (yes or no)Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 13 of 23

Controlled Document

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

4:25 PM 11

. Submit the form to the Green Mill Production Supervisor. The Green Mill Production Supervisor will

− Complete the SSM Incident Form

− File in the Green Mill Production Supervisor’s office

− Notify plant Environmental staff.

12

. Maintenance personnel are responsible for making appropriate entries into any maintenance logs.

13

. Retain records of each SSM event for five (5) years.

Table 3: Dry Scrubber low coke flow troubleshooting

Possible Causes Corrective Actions
Upstream mill dust failures cause inadequate fresh coke supply. Verify coke supply problems by observing load cells or silo weight measurements.

Initiate repair of screw conveyor, rotary

and/or PD blower.

Rotary air lock 510 at the base of fresh coke silo is not working properly. Initiate repair of rotary air lock.

Fresh coke silo is bridging and preventing the flow of coke to rotary air lock. Verify proper operation of fluid pads; initiate repair if necessary.

Use air hose to break up bridging.

Check coke flow monitoring devi ce for proper operation. Initiate process to repair monitoring device if necessary.

**Abnormal Visible Emissions**

In the event that emissions outside the normal operating range are visibly being emitted from the exhaust of this emission control system the f ollowing malfunction and corrective action plan must be initiated within one hour of first becoming aware of a

malfunction.

Examples of abnormal visible emissions or dusting stacks include, but are not limited to,

continuous visible emissions from the sta ck of the emission control device noted by the Operator.

During the initial response, the operator (or proxy) is to:

1

. Contact Paste Plant Supervisor, Maintenance Plant Supervisor, and /or appropriate Maintenance personnel to report the dusting stack from a ny source including, but not limited to, the daily visual checks made by Emission Control Personnel.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 14 of 23

Controlled Document

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

4:25 PM 2

. Log the time that the condition was first noticed or reported.

3

. Log the time at which he/she reported emissions or initiated this plan.

Following this in itial response, the operator (or proxy) and/or maintenance personnel

are to:

4

. Troubleshoot the system.

5

. If appropriate, use the guidance on Table 4, below, to determine the malfunction’s

cause.

6

. Make necessary repairs, equipment replacement, or process chan ges to remedy the situation in a safe, efficient, and timely manner.

7

. Verify that the repairs, equipment replacement, or process changes have remedied

the situation.

8

. If the action taken to remedy the situation fails to correct the problem, shut down the

an ode production process. Restart the process only after repairs, equipment replacement, or process changes have been completed and all malfunctions are

corrected.

9

. Describe the malfunction on the SSM Incident Form. Include the following

information:

− Date

− Nam e of person(s) completing form

− Description of malfunction

− Time of malfunction detection

− Time corrective action plan was initiated

− Details of actions taken.

− Time corrective action complete.

− Whether this Start up, Shut down, and Malfunction Plan was followed . (yes or no)

10

. Submit the form to the Green Mill Production Supervisor. The Green Mill Production Supervisor will

− Complete the SSM Incident Form

− File in the Green Mill Production Supervisor’s office

− Notify plant Environmental staff.

11

. Maintenance personnel are responsible for making appropriate entries into any maintenance logs.

12

. Retain records of each SSM event for five (5) years.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 15 of 23

Controlled Document

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

4:25 PM Table 4: Visible emissions troubleshooting

Possible Causes Corrective Actions Inspect baghouse on the dry scrubber system for broken bags or leaks. Replace or plug bags as necessary based on inspection findings.

**Continuous Parameter Monitoring System (CPMS) Malfunction**

Examples of lost monitoring of signals include, but are not limited to, an unexpected failure of the program mable logic controller (PLC) for more than:

• One hour while green mill is operating in any twenty

- four (24) hour period or a measurement device component failure that results in the loss of a signal that creates an hourly average annubar parametric measure ment below the established parametric limit.

• One hour while green mill is operating in any twenty

- four (24) hour period or a measurement device component failure that results in the loss of a signal that creates an hourly average coke flow parametric measu rement below the established parametric limit.

• Six (6) hours in any twenty

- four (24) hour period or loss of a measurement device component that results in a loss of Green Mill start and stop times that is below the

established limits.

The CPMS monitors th ree emission control system operating parameters: coke flow, airflow, and pitch flow. The monitors transmit data continuously to the PLC system in the Green Mill control room. The operator can monitor the coke flow and airflow on the

HMI Control Screen.

The pitch flowrate is monitored to ensure that the dry coke scrubber operating parameters are being monitored when the green mill is operating. There is no parametric limit for pitch flowrate. Having a failure in the pitch flowrate monitoring device

is not problematic as long as the coke flow and airflow monitoring devices are still operational and meeting parametric requirements.

If the airflow or coke flow monitoring devices fail, the PLC control screen displays an

alarm:

• If the coke flow monitor fai ls, the screen shows “0 lb/hr” and displays the Low Coke

Flow alarm.

• If the airflow monitor fails, the screen shows “0 cfm” and displays the Low Airflow

alarm.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 16 of 23

Controlled Document

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

4:25 PM Note: The operator should first follow the appropriate troubleshooting guide for low

airflo w (Table 2) and low coke flow (Table 3). If checking both airflow and coke flow confirms that a monitoring device failure is the problem, the operator initiate the following procedure:

In the event of the loss of the monitoring signal the following malfu nction and corrective action plan must be initiated within one hour of first becoming aware of the occurrence.

During the initial response, the operator (or proxy) is to:

1

. Log the time he/she first became aware of the loss of signal and the time at which

h e/she initiated corrective action.

2

. Confirm status of the monitoring system.

3

. Notify appropriate personnel such as maintenance and/or engineering to make necessary repairs.

Following this initial response, the appropriate personnel such as the operator (or proxy) and/or maintenance personnel are to:

4

. Make repairs, equipment replacements or to restart the PLC are to remedy the situation in a safe, efficient and timely manner. Refer to Table 5. for CPMS troubleshooting guidance.

5

. Describe the malfunction on the SSM Incident Form. Include the following

information:

− Date

− Name of person(s) completing form

− Description of malfunction

− Time of malfunction detection

− Time corrective action plan was initiated

− Details of actions taken.

− Time corrective action complete.

− Wheth er this Start up, Shut down, and Malfunction Plan was followed. (yes or no)

6

. Submit the form to the Green Mill Production Supervisor. The Green Mill Production Supervisor will:

− Complete the SSM Incident Form

− File in the Green Mill Production Supervisor’s office

− Notify plant Environmental staff.

7

. Maintenance personnel are responsible for making appropriate entries into any maintenance logs.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 17 of 23

Controlled Document

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

4:25 PM 8

. Retain records of each SSM event for five (5) years.

Table 5 : CPMS failure troubleshooting

Possible Causes Corrective Actions

Loss of communication between PLC

and HMI. Restart computer to re

- initialize

communication software or restart the specific software drivers.

Electrical supply lines or output lines

to/from instrumentation have failed. Initiate line repair.

Analog input module for PLC is not operational. Repair or replace module.

Coke Flow proximity switch that detects rotary air lock movement is not operational. Replace failed proximity switch.

Reinstall proximity switch in the proper

location to dete ct rotary air lock revolutions.

Airflow: Pitot tube differential pressure

transmitter used to calculate the airflow rate within the PLC is not operational. Check calibrations and electrical connections. Repair as necessary.

**Catastrophic Failure of Proce ss or Emission Control Equipment** 

In the event of catastrophic failure of process or emission control equipment, or components in this emission control system, the operator must initiate the following malfunction and corrective action plan within one hour of first becoming aware of a

malfunction.

Examples of catastrophic failure include, but are not limited to:

• Collapse of a unit or duct

• Direct lightning strike

• Loss of electrical power

• Earthquake

• Tornado

• System fire that results in uncontrolled emissions

As soon as the situation has become stable and hazards have been cleared, the operator or proxy is toAlcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 18 of 23

Controlled Document

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

4:25 PM 1

. Confirm the system status, noting which components are off line or otherwise impaired.

2

. Log the time that the condition was first noticed or reported a nd log the time at which he/she first began to respond to check the system status.

3

. Contact Paste Plant Supervisor or Maintenance Supervisor to initiate repairs to the monitoring device.

Following the initial response, the appropriate personnel such as the operator (or proxy ) and/or maintenance personnel are to:

4

. Make repairs, equipment replacements or process changes to remedy the situation in a safe, efficient and timely manner.

5

. Describe the malfunction on the SSM Incident Form. Include the following

infor mation:

− Date

− Name of person(s) completing form

− Description of malfunction

− Time of malfunction detection

− Time corrective action plan was initiated

− Details of actions taken.

− Time corrective action complete.

− Whether this Start up, Shut down, and Malfunction P lan was followed. (yes or no)

6

. Submit the form to the Green Mill Production Supervisor. The Green Mill Production Supervisor will:

− Complete the SSM Incident Form

− File in the Green Mill Production Supervisor’s office

− Notify plant Environmental staff.

7

. Maint enance personnel are responsible for making appropriate entries into any maintenance logs.

8

. Retain records of each SSM event for five (5) years.Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 19 of 23

Controlled Document

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

4:25 PM 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) requires all changes be reported in Semi

- annual Excess Emissions Report.

Revision

Date Nature of Revision Document Review Participants

04.04 .01 Rev. 0: Original Issuance D. Ringwald

11.15.04 Rev. 1 (Draft) Information from the previous Alcoa Intalco Works’ Green Mill SSM plan (last revised 04

- 04

- 2001) was incorporated into a new format based on template SSM plan for a similar process at ano ther Alcoa Facility. Kathryn Mitchell (Env. Engineer Anvil Corporation)

01.31.05 Date of Rev. 1 Revised with feedback from Carbon Plant (Roger Nordlund). Changed requirements for Startup and Shutdown reporting. Electronic data recording date

and duratio n will be used for routine startup and shutdown. Nonroutine will require an SSM report. Kathryn Mitchell Jim Schon (Intalco) (Reported to Ecology in 2005 First Semi Annual Excess Emissions Report).

2.18.05 Date of Rev. 2

Global revisions for definitions , clarifications, and consistency. No parametric changes. Kathryn Mitchell (Reported to Ecology in 2005 First Semi Annual Excess Emissions Report).

2.28.05 Rev. 3

Made clarifications to PMACT VE Event Flow Chart. Edited and Formatted by Tech. Writing

N o parametric changes. Kathryn Mitchell (Reported to Ecology in 2005 First Semi Annual Excess Emissions Report).

Aug. 18, 2005 Rev. 4

• Revised plan to reflect new lower airflow parametric of 46,000 as stated in revised

Parametric Plan.

• Deleted reference t o pitch pump operating parameter because it is not needed

— activation of the paste mixing system is not allowed per

electronic controls unless scrubber is operating

. Jim Schon, Kathryn Mitchell (Note: notified Ecology of SSMP plan change in

2005 2 nd semi an nual report.)Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 20 of 23

Controlled Document

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

4:25 PM Appendices

**Sample SSM Incident Form**

**PMACT Event Flow Chart**Alcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 21 of 23

Controlled Document

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

4:25 PM PMACT Event Flow Chart

VIOLATION

Notify

Environmental Staff

Make

Internal / External

Notifications

Submit

Internal / External Reports Yes

Archive Reports and Documentation

for

5 years Yes Abnormal

Visual

Emissions

Noted No Document Findings and Report Normally

No Yes

VIOLATION

SSM

Procedures

initiated within

1 hour ?

Yes

Yes No

SSM Plans

Followed ? VIOLATION No Yes SSM EventAlcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 22 of 23

Controlled Document

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

4:25 PM Sample SSM Incident Form

Date :

Name of person(s) completing this form (please print full name):

Air pollution control equipment:

Description of malfunction

Time of malfunction detection :

Time corrective action was initiated :

Describe in detail the corrective action initiated :

Time corrective action was completed :

Was the SSM plan followed? (yes or no)

:

Supervisor's signature

O: \ Info Share \ Controlled_Documents \ Environmental \ E3 Air Emission Management \ Carbon Plant \ Greenmill SSM Plan Current.doc

End of SSMAlcoa Intalco Works: Carbon Plant Green Mill Startup/Shutdown/Malfunction Plan

Department: Environmental Affairs Approval: J. Schon

Issue D ate: 04/04/01

Rev. No.: 4

Rev. Date: 08 / 18 /05 Page: 23 of 23

Controlled Document

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

4:25 PM Submittal Requirements



### 40 CFR Part 63‚ Section 850‚ Paragraph (c)

(c) Startup, shutdown, and malfunction plan and reports. The owner or operator shall develop and implement a written plan as described in §63.6(e)(3) that contains specific procedures to be followed for operating the source and maintaining the source during periods of startup, shutdown, and malfunction and a program of corrective action for malfunctioning process and control systems used to comply with the standard. The plan does not have to be submitted with the permit appplication or included in the operating permit. The permitting authority may review the plan upo n request. In addition to the information required in §63.6(e)(3), the plan shall include: