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, 2005
Alcoa Intalco Works: Carbon Plant

Green Mill Startup/Shutdown/Malfunction Plan 

Department: Environmental Affairs

Approval: J. Schon

Issue Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: i of 23

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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

Abnormal 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.......................................................................................... 20
Alcoa Intalco Works: Carbon Plant

Green Mill Startup/Shutdown/Malfunction Plan 

Department: Environmental Affairs

Approval: J. Schon

Issue Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 1 of 23

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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 malfunction. 

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 Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 2 of 23

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

Parameter 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 

averages of 1 

second 

readings

Hourly average 

valuesa

24 hr average

of 5 minute 

block 

averagesb

6.25 RPM 

(RPM at 4,500 

lb/hr)

Air flow

Annubar 

(EQ #: FE/FT0800) 

Continuous

during green 

mill operation

5 minute block 

averages of 1 

second 

readings

Hourly average 

valuesa

24 hr average

of 5 minute 

block 

averagesb

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 requirements, 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 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, including 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 Department 

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 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 Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 3 of 23

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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 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 7th day of each quarter 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 Environmental 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 days 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 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 equipment

Process Description

Anode production involves mixing calcined petroleum coke and anode scrap materials 

with coal tar pitch and forming these materials into 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 process 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 process.
Alcoa Intalco Works: Carbon Plant

Green Mill Startup/Shutdown/Malfunction Plan 

Department: Environmental Affairs

Approval: J. Schon

Issue Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 4 of 23

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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 and 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 droplets. 

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:

• The 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, an 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 normal 

startup.
Alcoa Intalco Works: Carbon Plant

Green Mill Startup/Shutdown/Malfunction Plan 

Department: Environmental Affairs

Approval: J. Schon

Issue Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 5 of 23

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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 corrective action complete

− Whether this Startup, Shutdown, and 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 Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 6 of 23

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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 Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 7 of 23

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Anode Production Process Shutdown

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

must be followed 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 appropriate 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 greenanode-forming equipment and emission control equipment. 

• Shutdown begins when pitch flow to the mixer is stopped, ending the ongoing 

production of green anode paste. 

• Shutdown concludes 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 requires 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 emission 

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 scheduled 

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 Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 8 of 23

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The paste production process is shut down through a request from the PLC in the 

Green Mill control room. Prior 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 after 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 components 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 process 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

− Description 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 Shutdown 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 completed.

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 Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 9 of 23

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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 flow 

• 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 with 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 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. 
Alcoa Intalco Works: Carbon Plant

Green Mill Startup/Shutdown/Malfunction Plan 

Department: Environmental Affairs

Approval: J. Schon

Issue Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 10 of 23

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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 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 airflow has returned to a level above the low airflow limit (54,000 

acfm).

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 

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.

− 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 Production 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 Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 11 of 23

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Table 2: Dry Scrubber low airflow troubleshooting 

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 damper 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 

H2O.

Maintain adequate pulse 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 monitoring 

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 capacity 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 rotary 
Alcoa Intalco Works: Carbon Plant

Green Mill Startup/Shutdown/Malfunction Plan 

Department: Environmental Affairs

Approval: J. Schon

Issue Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 12 of 23

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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 

malfunction 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 

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.

− 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 Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 13 of 23

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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

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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 device 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 following 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 stack 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 any 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 Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 14 of 23

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Controlled documents are maintained electronically as described in Document Control. Printed versions 

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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 initial 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 changes 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 

anode 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

− 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)

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 Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 15 of 23

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of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

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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 programmable 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 measurement 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 measurement 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 three 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 fails, 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 Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 16 of 23

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

airflow (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 malfunction 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 

he/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.

− Whether 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 Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 17 of 23

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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

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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 detect 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 Process 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 to 
Alcoa Intalco Works: Carbon Plant

Green Mill Startup/Shutdown/Malfunction Plan 

Department: Environmental Affairs

Approval: J. Schon

Issue Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 18 of 23

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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 and 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 

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.

− Whether 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.

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 Date: 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 following 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 another 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 duration 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

No 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 to 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 2nd semi annual report.) 
Alcoa Intalco Works: Carbon Plant

Green Mill Startup/Shutdown/Malfunction Plan 

Department: Environmental Affairs

Approval: J. Schon

Issue Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 20 of 23

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of documents are controlled up to 24 hours from the following print date/time: Last printed 11/01/2011

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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 Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 21 of 23

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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

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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 ?

No VIOLATION

Yes

SSM Event
Alcoa Intalco Works: Carbon Plant

Green Mill Startup/Shutdown/Malfunction Plan 

Department: Environmental Affairs

Approval: J. Schon

Issue Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 22 of 23

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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

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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:\InfoShare\Controlled_Documents\Environmental\E3 Air Emission 

Management\Carbon Plant\Greenmill SSM Plan Current.doc

End of SSM
Alcoa Intalco Works: Carbon Plant

Green Mill Startup/Shutdown/Malfunction Plan 

Department: Environmental Affairs

Approval: J. Schon

Issue Date: 04/04/01

Rev. No.: 4

Rev. Date: 08/18/05

Page: 23 of 23

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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

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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 upon request. In addition to the 

information required in §63.6(e)(3), the plan shall include: