A

Alcoa Inc

Intalco Works

National Emission Standards for Hazardous Air 

Pollutants for Primary Aluminum Reduction 

Plants

Potlines

Startup, Shutdown, and Malfunction Plan

Issued: Oct. 8, 1999

Current Rev. Date: June 1February 1, 2011, 2005
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: i of Appendix

Controlled Document

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

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

4:27 PM

Table of Contents

Introduction........................................................................................................................ 1

SSM Plan Requirements ............................................................................................. 2

Start-Up/Re-Start of Potlines ........................................................................................... 4

General Requirements................................................................................................. 4

Fume Treatment Center Operation.............................................................................. 5

Pot Operation Requirements ....................................................................................... 5

Shut-Down of Pot Line...................................................................................................... 7

Malfunction and Corrective Action Plans ...................................................................... 8

Malfunction and Corrective Action Plan Procedure Documentation ............................ 8

Low Air Flow (Process Gas) ........................................................................................ 9

Loss of Alumina Feed................................................................................................ 13

Low Flow of Water..................................................................................................... 14

Abnormal Visible Emissions - Dusting Stack(s)......................................................... 16

Loss of Parametric Monitoring Signals ...................................................................... 17

Catastrophic Failure of Process or Emission Control Equipment .............................. 18

Cold Weather Wet Roof Scrubber Shutdown ............................................................ 19

Revision Summary.......................................................................................................... 20

Appendices ...................................................................................................................... 21

Sample Start up, Shut down, Malfunction Exceedance Report ................................. 21

PMACT Event Flow Chart.......................................................................................... 21

SSOP: Cold Weather Shutdown/Start-Up EC-WS-0016 ........................................... 21

Introduction.......................................................................................................................... 1

SSM Plan Requirements ............................................................................................. 2

Start-Up/Re-Start of Potlines .............................................................................................. 4

Shut-Down of Pot Line ........................................................................................................ 5

Malfunction and Corrective Action Plans............................................................................ 6

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Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: ii of Appendix

Controlled Document

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

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

4:27 PM

Malfunction and Corrective Action Plan Procedure Documentation ............................ 6

Low Air Flow (Process Gas) ........................................................................................ 7

Loss of Alumina Feed................................................................................................ 11

Low Flow of Water..................................................................................................... 12

Abnormal Visible Emissions - Dusting Stack(s)......................................................... 14

Loss of Parametric Monitoring Signals ...................................................................... 15

Catastrophic Failure of Process or Emission Control Equipment .............................. 16

Cold Weather Wet Roof Scrubber Shutdown ............................................................ 17

Revision Summary ............................................................................................................ 18

Appendices........................................................................................................................ 19

Sample Start up, Shut down, Malfunction Exceedance Report ................................. 19

PMACT Event Flow Chart.......................................................................................... 19

SSOP: Cold Weather Shutdown/Start-Up EC-WS-0016 ........................................... 19

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Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 1 of Appendix

Controlled Document

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

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

4:27 PM

Introduction

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

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

events when potline 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.”

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

Ensure that, at all times, the owner or operator operates and maintains each affected 

source, including associated air pollution control and monitoring equipment, in a 

manner which satisfies the general duty to minimize emissions established by 

paragraph (e)(1)(i) of 40 CFR Part 63‚ Section 6.

Ensure that owners or operators are prepared to correct malfunctions as soon as 

practicable after their occurrence in order to minimize excess emissions of 

hazardous air pollutants; and 

Reduce the reporting burden associated with periods of startup, shutdown, and 

malfunction (including corrective action taken to restore malfunctioning process and 

air pollution control equipment to its normal or usual manner of operation). 

Notes regarding document control:

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

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

The Environmental Department Manager must approve any changes to this SSM plan.

The Corrective Action Plans described in this document must be initiated within one 

hour of first becoming aware that a parametric value was not achieved. Each parametric 

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

violation. 
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 2 of Appendix

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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. 

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.

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

Maintain records documenting the occurrence and duration of each startup, shutdown, 

or malfunction (refer to this plan for details).

Document maintenance performed on the air pollution control equipment.

Document actions taken during periods of SSM, including corrective actions to restore 

air pollution control equipment to normal operating conditions. 

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

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

SSM event.

Maintain documentation of each period of continuous monitoring system (CMS) 

malfunction or inoperative periods (including out of control periods, calibration 

periods, downtime, etc.).

Document all required measurements to demonstrate compliance with a relevant 

standard, including but not limited to all 24 hr average readings of CMS data.

Maintain documentation of all results of performance tests, CMS performance 

evaluations, and visible emission observations.

Document all CMS calibration checks performed. 

Document all adjustments and maintenance on CMS, including routine maintenance 

performed.

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.
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 3 of Appendix

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

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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. 

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
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 4 of Appendix

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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

4:27 PM

Start-Up/Re-Start of Potlines

In the event that a start-up or re-start of the of pot lines A, B or C (or portion thereof) 

served by the primary control and secondary roof scrubbers (devices) creates or leads 

to a situation that causes operation outside of appropriate parametric ranges for 

process air flow, alumina flow, or water flow (to the wet scrubbers) the following StartUp plan must be initiated within one hour of first becoming aware of the situation.

A start-up or re-start is defined as the process of re-energizing an idled section of 

aluminum reduction cells (pot) and that is serviced by an idled potline primary control 

device and secondary roof scrubbers (device). The start-up or re-start begins when the 

first idled pot is energized. The start-up or re-start concludes when the last of the pots 

that have been scheduled to be started or re-started has been energized. 

Appropriate limits for parametric ranges during a re-start or start-up are determined by 

multiplying the limits for parametric ranges that have been approved for a full section of 

pots connected to an operational primary control device by the fraction of pots operating 

that are attached to the control device affected by the re-start or start-up. (Fraction = 

No. Pots Operating/120 Pots per control device on A line and 60 on B&C Line.)

General Requirements

1) Intalco must assign a pot line start-up coordinator.

2) Training on emission control procedures must be completed prior to start-up for all 

personnel involved in pot line start-up.

3) A projected schedule for the pot line start-up must be completed. Individual pot 

start-up rates will be dictated by available bath. The schedule is subject to change 

as conditions dictate.

4) Records must be kept of the total pots started each day.

5) The startup of the first pot in the potline must be logged in the SSM Log. 

6) The start-up period must not exceed 6 months.

7) In the event of operation outside of approved parametric limits during startup or

restart conditions, the Operator is to assure that the ratio of pots operating to control 

device compartments on line does not exceed 20 for A line and 5 for B & C line. If 

this ratio does exceed 20 for A line and 5 for B & C line, then an additional Control 

Device compartment is to be put on line. (This ratio of a minimum of 20 for A line 

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Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 5 of Appendix

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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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and 5 for B & C line for each control device compartment applies only during start-up 

and re-start conditions to assure a consistently high minimum process gas flow rate 

to all pots that have been started or re-started.)

1) 

8) The start-up or re-start concludes after the last control device compartment that has 

been scheduled for re-start has been energized. This should coincide with or follows

the addition of liquid bath to the last re-start pot and may overlap into a period of 

normal pot start-ups. 

9) Records of the start-up must be retained for five (5) years. Should an exceedence

occur, it is to be entered into the semi-annual reporting period log kept by the 

Environmental Department and be reported in the monthly air operating report 

submitted for the month in question.

Fume Treatment Center Operation

1) The Operator must assure that prior to adding liquid bath to the first pot, alumina flow 

and airflow is set above the parametric limit established in the facility’s Parametric 

Monitoring Plan. 

Pot Operation Requirements

1) Prior to energizing a pot the following activities must be performed:

− A hood condition survey must be completed.

− Repairs to the pots must be completed, and hoods must be replaced if 

necessary.

− The fume take-off ducts in the superstructure of the pot must be cleaned as 

required. 

2) Potline startup procedures must include the following steps, adjusted as necessary to 

minimize emissions and energy consumption.

− All solid bath, alumina and metal will be removed from the old cathodes.

− Graphite resistor material will be placed on the cathode per specific procedures 

and the anodes placed onto the resistor.

− The pot will be energized and “baked” electrically prior to molten bath being 

poured into the reduction cell(s).

− After baking, molten bath (either melted or tapped from other pots) will be added 

to the pot and the anodes pulled up off the resistor.

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Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 6 of Appendix

Controlled Document

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

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

4:27 PM

− Approximately 8-12 hours after the pull up, molten aluminum will be added to the 

pot to improve stability and maintain proper heat balance.

− Potroom supervisors and operators will monitor and adjust cell voltage, alumina 

feed rate, liquid level, and bath temperature in order to achieve normal operation 

and avoid instability.

3) After energizing a pot the following activities must be performed:

− Pot hoods must be in place on all operating pots except when performing 

necessary work activities.

− Damaged hoods must be repaired and/or replaced promptly in accordance with 

the pot hood policy in condition H4.e of Intalco’s AOP. Hoods will be assessed 

based on their ability to capture emissions and prevent fugitive emissions.

− Procedures for normal operation must be in place during startup:

• Pot hood policy dated 6/15/2009.

• Fume control system operation dated 11/29/2007.

• Pot cut-outs dated 4/16/2010.

− All potroom floors must be cleaned at least once per day.

2) Records of the start-up are to be retained for five (5) years. Should an exceedence

occur, it is to be entered into the semi-annual reporting period log kept by the 

Environmental Department and be reported in the monthly air operating report 

submitted for the month in question.

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Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 7 of Appendix

Controlled Document

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

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

4:27 PM

Shut-Down of Pot Line 

In the event that a shut-down of Pot Lines A, B or C (or portion thereof) served by the 

primary and secondary control systems (devices) creates or leads to a situation that 

causes operation outside of appropriate parametric ranges for process gas flow, 

alumina flow or water flow (to the wet scrubbers) the following Shut-Down plan must

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

A shut-down is defined as the process of allowing a complete section of aluminum 

reduction cells that are serviced by a common potline primary control device and 

secondary roof scrubbers (devices) to freeze solid the contents of liquid bath and metal. 

The shutdown begins when electrical power has been intentionally discontinued for the 

purpose of a shut down or 24 hours after a sustained unintentional loss of electrical 

power. The shutdown concludes 48 hours after service of electrical power has been 

discontinued. Appropriate limits for parametric ranges during a shut-down are 

determined by multiplying the limits for parametric ranges that have been approved for a 

full section of pots connected to an operational primary control device by the fraction of 

pots operating that are attached to the primary control device affected by the shut-down 

(Fraction = No. Pots Operating/120 Pots per Control Device on A line and 60 on B&C 

Line)

1) In the event of operation outside of approved parametric limits the Operator is to 

assure that throughout the shut-down, sufficient primary control device 

compartments are to be kept operating such that a ratio of a minimum of 20 for A 

line and 5 for B & C line primary control device compartments are maintained. The 

Operator is to assure that both primary and secondary control systems are on and 

that sufficient airflow (draft) and ore flow (alumina) for primary devices and water 

flow for the secondary devices are functioning –running for the appropriate control 

device servicing the pot and or section being shut down.

2) After 48 hours of cooling time, the liquid contents of the aluminum reduction cells will 

have frozen and ceased to give off gaseous emissions. Primary control device 

compartments and secondary roof scrubbers may be shut down any time after 48 

hours have elapsed. 

3) Records of the start-up are to be retained for five (5) years. Should an exceedence

occur, it is to be entered into the semi-annual reporting period log kept by the 

Environmental Department and be reported in the monthly air operating report 

submitted for the month in question.
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 8 of Appendix

Controlled Document

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

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

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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 (Process Gas)

Loss of Alumina Feed

Low Flow of Water

Abnormal Visible Emissions - Dusting Stack(s)

Loss of Parametric Monitoring Signals

Catastrophic Failure of Process or Emission Control Equipment

Cold Weather Wet Roof Scrubber Shutdown

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
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 9 of Appendix

Controlled Document

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

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

4:27 PM

Low Air Flow (Process Gas)

In the event of low flow of process gas (a.k.a.- low air flow) through this primary control 

system (device) the following malfunction and corrective action plan must be initiated 

within one hour of first becoming aware of a malfunction.

Examples of low flow conditions include, but are not limited to; unexpected loss of 

electrical power from severe weather and reductions in flow due to unplanned primary 

control device compartment outages that result in simultaneous multiple compartment 

downtime within this control device that generates an inlet duct flow parametric that is 

below operational limits. Refer below to “Appendix B, Low Air Flow Requirements Under 

Curtailment Conditions” which is from the Parametric Monitoring Plan, Rev. 3 and also 

includes low air flow operational limits during full production.

1) The operator is to confirm the system status, noting which primary control device 

compartments are either off line or otherwise impaired. The operator is to log the 

time that the condition was first noticed or reported and also log the time at which 

he/she first began to respond to check the system status.

2) Following this initial response, the operator or proxy is to notify appropriate 

maintenance personnel and/or initiate a maintenance work order, or restart the 

unit(s) in events such as momentary loss of power.

3) Personnel responding to the malfunction are to make repair(s), equipment 

replacement(s) or process change(s) to remedy the situation in a safe and efficient 

manner. 

4) The system operator or proxy will be responsible for logging the duration of the 

malfunction and the cause. Maintenance personnel will be responsible for making 

appropriate entries into any maintenance logs.

5) Records of the start-up are to be retained for five (5) years. Should an exceedence

occur, it is to be entered into the semi-annual reporting period log kept by the 

Environmental Department and be reported in the monthly air operating report 

submitted for the month in question.
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 10 of Appendix

Controlled Document

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

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

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Air Flow Operational Limits for “A” Potline

Potline Control Device 1 Potline Control Device 2

# of Pots Served 

by Control Device

Normal Airflow 

(ACFM)

Operational 

Limit (ACFM)

# of Pots Served 

by Control Device

Normal Airflow 

(ACFM)

Operational 

Limit (ACFM)

117 to 120 177,000 141,000 117 to 120 176,000 141,000

113 to 116 171,100 136,300 113 to 116 170,133 136,300

109 to 112 165,200 131,600 109 to 112 164,267 131,600

105 to 108 159,300 126,900 105 to 108 158,400 126,900

101 to 104 153,400 122,200 101 to 104 152,533 122,200

97 to 100 147,500 117,500 97 to 100 146,667 117,500

93 to 96 141,600 112,800 93 to 96 140,800 112,800

89 to 92 135,700 108,100 89 to 92 134,933 108,100

85 to 88 129,800 103,400 85 to 88 129,067 103,400

81 to 84 123,900 98,700 81 to 84 123,200 98,700

77 to 80 118,000 94,000 77 to 80 117,333 94,000

73 to 76 112,100 89,300 73 to 76 111,467 89,300

69 to 72 106,200 84,600 69 to 72 105,600 84,600

65 to 68 100,300 79,900 65 to 68 99,733 79,900

61 to 64 94,400 75,200 61 to 64 93,867 75,200

57 to 60 88,500 70,500 57 to 60 88,000 70,500

53 to 56 82,600 65,800 53 to 56 82,133 65,800

49 to 52 76,700 61,100 49 to 52 76,267 61,100

45 to 48 70,800 56,400 45 to 48 70,400 56,400

41 to 44 64,900 51,700 41 to 44 64,533 51,700

37 to 40 59,000 47,000 37 to 40 58,667 47,000

33 to 36 53,100 42,300 33 to 36 52,800 42,300

29 to 32 47,200 37,600 29 to 32 46,933 37,600

25 to 28 41,300 32,900 25 to 28 41,067 32,900

21 to 24 35,400 28,200 21 to 24 35,200 28,200

17 to 20 29,500 23,500 17 to 20 29,333 23,500
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 11 of Appendix

Controlled Document

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

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

4:27 PM

Air Flow Operational Limits for “B” Potline

Potline Control Device 3 North Potline Control Device 3 South

# of Pots Served 

by Control Device

Normal Airflow 

(ACFM)

Operational 

Limit (ACFM)

# of Pots Served 

by Control Device

Normal Airflow 

(ACFM)

Operational 

Limit (ACFM)

57 to 60 131,000 105,000 57 to 60 167,000 134,000

53 to 56 122,267 98,000 53 to 56 155,867 125,067

49 to 52 113,533 91,000 49 to 52 144,733 116,133

45 to 48 104,800 84,000 45 to 48 133,600 107,200

41 to 44 96,067 77,000 41 to 44 122,467 98,267

37 to 40 87,333 70,000 37 to 40 111,333 89,333

33 to 36 78,600 63,000 33 to 36 100,200 80,400

29 to 32 69,867 56,000 29 to 32 89,067 71,467

25 to 28 61,133 49,000 25 to 28 77,933 62,533

21 to 24 52,400 42,000 21 to 24 66,800 53,600

17 to 20 43,667 35,000 17 to 20 55,667 44,667

13 to 16 34,933 28,000 13 to 16 44,533 35,733

9 to 12 26,200 21,000 9 to 12 33,400 26,800

Potline Control Device 4 North Potline Control Device 4 South

# of Pots Served 

by Control Device

Normal Airflow 

(ACFM)

Operational 

Limit (ACFM)

# of Pots Served 

by Control Device

Normal Airflow 

(ACFM)

Operational 

Limit (ACFM)

57 to 60 154,000 123,000 57 to 60 148,000 118,000

53 to 56 143,733 114,800 53 to 56 138,133 110,133

49 to 52 133,467 106,600 49 to 52 128,267 102,267

45 to 48 123,200 98,400 45 to 48 118,400 94,400

41 to 44 112,933 90,200 41 to 44 108,533 86,533

37 to 40 102,667 82,000 37 to 40 98,667 78,667

33 to 36 92,400 73,800 33 to 36 88,800 70,800

29 to 32 82,133 65,600 29 to 32 78,933 62,933

25 to 28 71,867 57,400 25 to 28 69,067 55,067

21 to 24 61,600 49,200 21 to 24 59,200 47,200

17 to 20 51,333 41,000 17 to 20 49,333 39,333

13 to 16 41,067 32,800 13 to 16 39,467 31,467

9 to 12 30,800 24,600 9 to 12 29,600 23,600
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 12 of Appendix

Controlled Document

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

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

4:27 PM

Air Flow Operational Limits for “C” Potline

Potline Control Device 5 North Potline Control Device 5 South

# of Pots Served 

by Control Device

Normal Airflow 

(ACFM)

Operational 

Limit (ACFM)

# of Pots Served 

by Control Device

Normal Airflow 

(ACFM)

Operational 

Limit (ACFM)

57 to 60 107,000 85,000 57 to 60 129,000 103,000

53 to 56 99,867 79,333 53 to 56 120,400 96,133

49 to 52 92,733 73,667 49 to 52 111,800 89,267

45 to 48 85,600 68,000 45 to 48 103,200 82,400

41 to 44 78,467 62,333 41 to 44 94,600 75,533

37 to 40 71,333 56,667 37 to 40 86,000 68,667

33 to 36 64,200 51,000 33 to 36 77,400 61,800

29 to 32 57,067 45,333 29 to 32 68,800 54,933

25 to 28 49,933 39,667 25 to 28 60,200 48,067

21 to 24 42,800 34,000 21 to 24 51,600 41,200

17 to 20 35,667 28,333 17 to 20 43,000 34,333

13 to 16 28,533 22,667 13 to 16 34,400 27,467

9 to 12 21,400 17,000 9 to 12 25,800 20,600

Potline Control Device 6 North Potline Control Device 6 South

# of Pots Served 

by Control Device

Normal Airflow 

(ACFM)

Operational 

Limit (ACFM)

# of Pots Served 

by Control Device

Normal Airflow 

(ACFM)

Operational 

Limit (ACFM)

57 to 60 129,000 103,000 57 to 60 129,000 103,000

53 to 56 120,400 96,133 53 to 56 120,400 96,133

49 to 52 111,800 89,267 49 to 52 111,800 89,267

45 to 48 103,200 82,400 45 to 48 103,200 82,400

41 to 44 94,600 75,533 41 to 44 94,600 75,533

37 to 40 86,000 68,667 37 to 40 86,000 68,667

33 to 36 77,400 61,800 33 to 36 77,400 61,800

29 to 32 68,800 54,933 29 to 32 68,800 54,933

25 to 28 60,200 48,067 25 to 28 60,200 48,067

21 to 24 51,600 41,200 21 to 24 51,600 41,200

17 to 20 43,000 34,333 17 to 20 43,000 34,333

13 to 16 34,400 27,467 13 to 16 34,400 27,467

9 to 12 25,800 20,600 9 to 12 25,800 20,600
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 13 of Appendix

Controlled Document

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

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

4:27 PM

Loss of Alumina Feed

In the event of loss of alumina feed through this primary control device the following 

malfunction and corrective action plan must be initiated within one hour of first 

becoming aware of a malfunction.

Examples of loss of alumina feed include, but are not limited to: alumina feed line failure 

from ore truck to control device, ore truck(s) late or unable to deliver due to mechanical 

problems or adverse weather conditions, failure of the alumina delivery system from silo 

to ore truck, and alumina shortage due to ship scheduling, unloading or weather related 

problems. Refer to table below “Operational Limits for Alumina Flow on Potline Control 

Devices” which is Table 2.2 in the Parametric Monitoring Plan, Rev. 3.

Operational Limits for Alumina Flow on Potline Control Devices

Potline Parameter Measurement Operational Limit Compliance 

Period

A Alumina Flow Consecutive Minutes 

on Total Recycle 900 minutes Potroom Cycle (20 hrs)

B Alumina Flow Consecutive Minutes 

on Total Recycle 300 minutes Potroom Cycle (20 hrs)

C Alumina Flow Consecutive Minutes 

on Total Recycle 300 minutes Potroom Cycle (20 hrs)

1) The operator is to confirm the system status, noting how long the system has been 

on recycle and the parametric limit for the particular control device. The operator is 

to log the time that the condition was first noticed or reported and also log the time at 

which they first began to initiate corrective action.

2) Following this initial response, the operator or proxy is to initiate corrective action by 

notifying the appropriate maintenance personnel and/or initiating a maintenance 

work order.

3) Personnel responding to the malfunction are to make repairs, replace equipment, or 

make process changes to remedy the situation in a safe and efficient manner.

4) The system operator or proxy will be responsible for logging the duration of the 

malfunction and the cause. Maintenance personnel will be responsible for making 

appropriate entries into any maintenance logs.

5) Records of the start-up are to be retained for five (5) years. Should an exceedence

occur, it is to be entered into the semi-annual reporting period log kept by the 

Environmental Department and be reported in the monthly air operating report 

submitted for the month in question.
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 14 of Appendix

Controlled Document

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

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

4:27 PM

Low Flow of Water

In the event of low flow of water through this secondary control system (device) the 

following malfunction and corrective action plan must be initiated within one hour of 

first becoming aware of a malfunction.

Examples of low flow conditions include, but are not limited to; unexpected loss of 

electrical power from severe weather and reductions in flow due to unplanned 

secondary control device compartment outages that result in simultaneous multiple 

compartment downtime within this control device that generates a water flow parametric 

that is below acceptable limits. Refer to table below for “Water Flow Operational Limits” 

which combines table 3.2 and the table in Appendix C from the Parametric Monitoring 

Plan.

Water Flow Operational Limits 

Potline # of Pot Sections 

Operating

Normal Water Flow (1) 

gallons/day 

(each 24-hour period)

Operational Limit (2)

gallons/day 

(each 24-hour period)

A

1 - 2 255,000 180,000 

3 - 4 509,200 360,000 

5 - 6 1,050,000 683,000

B

1 - 2 278,000 180,700 

3 - 4 556,560 361,764 

5 - 6 983,000 639,000

C

1 - 2 284,000 184,600 

3 - 4 567,290 368,739 

5 - 6 794,000 516,000

1. Based on short-term average data for combined recycle water flow for both buildings of each potline

2. 65% of short term average data for combined water flow for both buildings of each potline

1) The operator is to confirm the system status, noting which secondary control device 

compartments are either off line or otherwise impaired. The operator is to log the 

time that the condition was first noticed or reported and also log the time at which 

he/she first began to respond to check the system status.

2) Following this initial response, the operator or proxy is to notify appropriate 

maintenance personnel and/or initiate a maintenance work order, or restart the 

unit(s) in events such as momentary loss of power.

3) Personnel responding to the malfunction are to make repair(s), equipment 

replacement(s) or process change(s) to remedy the situation in a safe and efficient 

manner. 
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 15 of Appendix

Controlled Document

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

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

4:27 PM

4) The system operator or proxy will be responsible for logging the duration of the 

malfunction and the cause. Maintenance personnel will be responsible for making 

appropriate entries into any maintenance logs.

5) Records of the start-up are to be retained for five (5) years. Should an exceedence

occur, it is to be entered into the semi-annual reporting period log kept by the 

Environmental Department and be reported in the monthly air operating report 

submitted for the month in question.

6) In the event of a sudden or predicted change in the weather and the temperature 

drops below freezing, the water treatment operator will begin monitoring the wet 

scrubber conditions. When conditions indicate freezing is occurring, the water 

treatment operator will take appropriate action to prevent freeze damage by 

following the Cold Weather Wet Roof Scrubber Shutdown Procedures in this plan.
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 16 of Appendix

Controlled Document

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

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

4:27 PM

Abnormal Visible Emissions - Dusting Stack(s)

In the event of abnormal visible emissions, dusting stack(s), for the primary control 

devices or the secondary wet scrubbers (devices) the following malfunction and 

corrective action plan must be initiated within one hour of first becoming aware of a 

malfunction.

Examples of visible emissions or dusting stack(s) include, but are not limited to; 

continuous visible emissions noted by the Operator from any stack in the primary 

control device or secondary roof scrubber (mist eliminator).

1) The operator is to confirm any report of a dusting stack(s) from any source including, 

but not limited to the daily visual checks made by the Operator. The operator is to 

log the time that the condition was first noticed or reported and also log the time at 

which he/she made confirmation of the report.

2) Following this initial response, the operator or proxy is to make arrangements to 

have the appropriate compartment(s) shut down to make repairs.

3) Personnel responding to the malfunction are to make repair(s) to remedy the 

situation in a safe and efficient manner.

4) The system operator or proxy will be responsible for logging the event in the visible 

emission log. Maintenance personnel will be responsible for making appropriate 

entries into any maintenance logs.

5) Records of the start-up are to be retained for five (5) years. Should an exceedence

occur, it is to be entered into the semi-annual reporting period log kept by the 

Environmental Department and be reported in the monthly air operating report 

submitted for the month in question.
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 17 of Appendix

Controlled Document

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

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

4:27 PM

Loss of Parametric Monitoring Signals 

In the event of loss of fresh alumina feed, air flow or water flow signal(s) for the primary 

and secondary control device the following malfunction and corrective action plan must

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

Examples of a loss of signal include, but are not limited to; unexpected failure of the 

programmable logic controller, PLC, loss of an annubar flowmeter device for the airflow 

parametric or the flowmeter(s) that monitor water flow in the wet scrubbers for A,B and 

C potlines .

1) The operator is to confirm the system status, noting if the PLC is off line or which 

Control Device) equipment have suffered signal loss. The operator is to log the time 

that the condition was first noticed or reported and also log the time at which he/she 

first began to respond to check the system status.

2) Following this initial response, the operator or proxy is to notify appropriate 

maintenance personnel and/or initiate a maintenance work order, or restart the PLC 

in an event such as momentary loss of power.

3) Personnel responding to the malfunction are to make repair(s), equipment 

replacement(s) or process change(s) to remedy the situation in a safe and efficient 

manner.

4) The system operator or proxy will be responsible for logging the duration of the 

malfunction and the cause. Maintenance personnel will be responsible for making 

appropriate entries into any maintenance logs.

5) Records of the start-up are to be retained for five (5) years. Should an exceedence

occur, it is to be entered into the semi-annual reporting period log kept by the 

Environmental Department and be reported in the monthly air operating report 

submitted for the month in question.
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 18 of Appendix

Controlled Document

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

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

4:27 PM

Catastrophic Failure of Process or Emission Control Equipment 

In the event of catastrophic failure of Emission control equipment or components in the 

primary or secondary control system (devices) the following malfunction and corrective 

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

Examples of catastrophic failure include, but are not limited to; collapse of a primary or 

secondary control devices units or inlet ducts, a direct lightning strike, an earthquake, or 

a system fire that results in uncontrolled emissions.

1) As soon as the situation has become stable and hazards have been cleared, the 

operator or proxy is to confirm the system status, noting which primary and 

secondary control device compartments are either off line or otherwise impaired. 

The operator is to log the time that the condition was first noticed or reported and 

also log the time at which he/she first began to respond to check the system status.

2) Following this initial response, the operator or proxy is to notify appropriate 

maintenance, engineering and support personnel.

3) Personnel responding to the malfunction are to make repair(s), equipment 

replacement(s) or process change(s) to remedy the situation in a safe and efficient 

manner. In certain situations, location management may need to evaluate 

discontinuing the operation of some smelting cells. Such decisions may initiate 

appropriate Shut Down plans.

4) The system operator or proxy will be responsible for logging the duration of the 

malfunction. Maintenance personnel will be responsible for making appropriate 

entries into any maintenance logs.

5) Records of the start-up are to be retained for five (5) years. Should an exceedence

occur, it is to be entered into the semi-annual reporting period log kept by the 

Environmental Department and be reported in the monthly air operating report 

submitted for the month in question.
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 19 of Appendix

Controlled Document

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

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

4:27 PM

Cold Weather Wet Roof Scrubber Shutdown

The primary wastewater treatment plant operator is responsible for monitoring weather 

conditions that could impact the wet roof scrubber and wastewater treatment 

operations. In the event of a sudden or predicted change in the weather and the 

temperature drops below freezing and wind direction is from the northeast, the primary 

wastewater treatment plant operator will begin monitoring the condition of the roof 

scrubber nearest the doorway at the north end of each pot building. When conditions 

indicate freezing is occurring and wet roof scrubber shut is required, the water treatment 

operator will take the actions described in SSOP: Cold Weather Shutdown/Start-Up 

EC-WS-0016 (refer to appendix) to prevent freeze damage. This activity is designed 

to minimize wet scrubber down time and damage that could be caused by cold 

temperatures.

While recognizing that weather conditions may impact labor availability, Intalco will 

make a good faith effort to implement an alternate potroom Standard Operating 

Procedure (SOP) during periods when the roof scrubbers are not operating. The 

alternate SOP will limit the number of hoods to one per 20 pot section.

1) Personnel shutting down wet roof scrubbers are to follow SSOP: Cold Weather 

Shutdown/Start-Up EC-WS-0016.

2) As described in step 1. Cold Weather Shutdown of SSOP: Cold Weather 

Shutdown/Start-Up EC-WS-0016, the operator is to confirm freezing conditions are 

causing ice buildup on the spray arms of the northern most scrubber operating. 

3) As described in step 1. Cold Weather Shutdown of SSOP: Cold Weather 

Shutdown/Start-Up EC-WS-0016, the operator is to notify Environmental 

Department prior to shutting down the wet roof scrubbers.

4) The system operator or proxy will be responsible for logging the time shut down 

occurred, the duration of the shutdown, and the cause.

5) Records of the shutdown are to be retained for five (5) years. Should an 

exceedence occur, it is to be entered into the semi-annual reporting period log kept 

by the Environmental Department and be reported in the monthly air operating report 

submitted for the month in question.
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 20 of Appendix

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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

4:27 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

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

Oct. 10, 1999 Added Cold Weather Shutdown

May 20, 2005 Previous SSM Plan was separated into 

two documents: SSM Plan Anode Bake 

Ovens and this SSM Plan for Potlines. No 

parametric content changed. The 

following formatting, editing, and 

clarifications were made:

• Updated tables with parametric limits 

to be consistent with Parametric Plan 

Rev. 3.

• Added Controlled Document 

Elements.

• Replaced “Low Alumina Flow” with 

“Loss of Alumina Feed”

• Added Example “Sample Start up, 

Shut down, Malfunction Exceedance 

Report”

• Revised PMACT Event Flowchart to 

clarify Emission Control’s 

responsibilities versus Environmental 

Department.

• Revised Introduction.

• Transferred all Bake Oven information 

to a new “Bake Oven Startup, 

Shutdown, and Malfunction Plan.

• Changed formatting of the Cold 

Weather Wet Roof Scrubber 

Shutdown to be consistent with Intalco 

SSOP and moved it to the Appendix.

Jim Schon, Dave Ringwald, Brad 

Oxford, Kathryn Mitchell (Anvil)

(Reported to Ecology in 2005 First Semi 

Annual Excess Emissions Report).

Feb 1, 2011 Revised Potline Startup procedure to 

comply with Order #8356

Kathryn Mitchell

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Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 21 of Appendix

Controlled Document

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

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

4:27 PM

Appendices

Sample Start up, Shut down, Malfunction Exceedance Report

PMACT Event Flow Chart

SSOP: Cold Weather Shutdown/Start-Up EC-WS-0016
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 1 of Appendix

Controlled Document

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

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

4:27 PM

Startup, Shutdown, Malfunction / Operating Limit 

Exceedance Report

Control Device:

_______________________

Date/Time of SSM Event / Exceedance was detected:

Describe Cause of SSM Event / Exceedance (if known):

Time Corrective Action Started:

Describe Corrective Action:

Was the SSM Plan Followed? (Circle one): Yes / No

Reported by:

(Name) (Badge #)

This form is to be forwarded to your supervisor as soon as practicable. An email alert to your supervisor is also 

requested.

Air Flow 

Fresh Ore Flow 

Water Flow 

Abnormal Visible Emission 

Loss of Parametric Monitoring Signals 

Catastrophic Failure of Emission Control Equipment 

Cold Weather Shutdown 
Alcoa Intalco Works

Potlines Startup/Shutdown/Malfunction Plan 

Department: Environmental

Approval: Jim SchonKathryn 

Mitchell

Issue Date: 10.08.88

Rev. No.: 23

Rev. Date: 0602.01.0511

Page: 2 of Appendix

Controlled Document

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

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

4:27 PM

PMACT Event Flow Chart 

Notify 

Environmental Staff

Day shift, notify immediately

Night shift, notify on the following 

working day.

Make 

Internal / External

Notifications

Submit

Internal / External

Reports

Archive 

Reports and Documentation

 for 

5 years

Yes

SSMP 

Event

VIOLATION

SSM 

Procedures 

initiated within 

1 hour?

Yes

Yes

No

SSM Plans 

Followed ?

No VIOLATION

Yes
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 4:27 PM

SSOP: Cold Weather Shutdown/Start-Up EC-WS-0016

A Emission Control

Intalco Works - Safety and Standard Operating Procedure

Approval: Pat Pollock 

Author: J. Goertz

Date: 8/25

Rev. #: 1

Doc. #: EC-WS-0016

CC:

Job Title: Cold Weather Shutdown/Start-Up

References: Alcoa Safety Protocols

Purpose: Shut Down And Drain The System To Minimize Or Prevent Freeze Damage To The Equipment. This Operation Will Be Done 

Using Methods To Avoid Accidental Water Spills To The Process Or Storm Sewers And To Facilitate A Quick And Orderly Restart Of The 

Wet Scrubbers.

Equipment Required: Screw Driver, Channel Lock Pliers, Hose Cutting Tools

PPE: Safety Boots, Hard Hat, Safety Glasses, Ear Protection, Approved Respirator, Are Required For All Production Area Jobs.

JOB STEPS

PROPER WORK METHOD AND JOB ANALYSIS

(Equipment, Technology, Procedure)

HEALTH & SAFETY

HAZARDS ENVIRONMENT

1. Cold Weather 

Shutdown 

In the event of a sudden or predicted change in the weather 

and the temperature dips below freezing, the Water 

Treatment Plant Operator will begin monitoring the Wet 

Scrubber conditions. When conditions indicate freezing 

is occurring, the water treatment plant operator will take 

appropriate action to prevent freeze damage

a) Notify Emission Control Supervision. The Emission 

Control Water Treatment Plant Operator on shift will 

inspect inside the Northern most Scrubbers to check 

for Ice buildup on the spray arms or on the tanks.

b) Maintenance will shut down the process (P.U.D.) 

water south of each Potline building and drain the 

system as per their attached procedure.

c) Wet Scrubber operators are to be called in by the 

Immediately contact Env. 

Dept. because the 

Department of Ecology 

must be notified when roof 

scrubbers are going to be 

shut off (per Air Operating 

Permit condition D3)
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 4:27 PM

A Emission Control

Intalco Works - Safety and Standard Operating Procedure

Approval: Pat Pollock 

Author: J. Goertz

Date: 8/25

Rev. #: 1

Doc. #: EC-WS-0016

CC:

Job Title: Cold Weather Shutdown/Start-Up

References: Alcoa Safety Protocols

Purpose: Shut Down And Drain The System To Minimize Or Prevent Freeze Damage To The Equipment. This Operation Will Be Done 

Using Methods To Avoid Accidental Water Spills To The Process Or Storm Sewers And To Facilitate A Quick And Orderly Restart Of The 

Wet Scrubbers.

Equipment Required: Screw Driver, Channel Lock Pliers, Hose Cutting Tools

PPE: Safety Boots, Hard Hat, Safety Glasses, Ear Protection, Approved Respirator, Are Required For All Production Area Jobs.

JOB STEPS

PROPER WORK METHOD AND JOB ANALYSIS

(Equipment, Technology, Procedure)

HEALTH & SAFETY

HAZARDS ENVIRONMENT

Emission Control Water Treatment Plant Operator 

on shift if icing is occurring and it becomes 

necessary to shut down the Scrubbers.

Always attempt to allow time for an orderly shutdown

2. (P.U.D.) 

Process 

Water System 

Shutdown In 

The Potline 

Area

a) Process Water System Shutdown is to be initiated by 

Maintenance and to be shut down by Maintenance 

(Hood-Repair Shop/Environmental Maintenance)

b) Maintenance will notify Pot Relining and Emission 

Control prior to shutdown.

c) When main process water valve has been shut off and 

the Process (P.U.D.) line has been drained at the south 

end of the building by Maintenance, proceed to open all 

the Process (P.U.D.) Water valves on the scrubber deck

d) The process (P.U.D.) water will usually be shut down and 

drained when the ambient temperatures are expected to 

Many of the valves, 

clamps and other 

items that need to 

be accessed are 

encased inside the 

steel “I” beam 

framework that 

supports the 

individual Scrubber 

Units. A person has 

to be mindful of the 

The shutting down of the 

respective water systems 

that feed the Wet 

Scrubbers in effect shuts 

down any pollutant capture 

capability of the Wet 

Scrubber System. With the 

fans left running, the Wet 

Scrubbers are nothing 

more than large air movers 

that ventilate the Pots 
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 4:27 PM

A Emission Control

Intalco Works - Safety and Standard Operating Procedure

Approval: Pat Pollock 

Author: J. Goertz

Date: 8/25

Rev. #: 1

Doc. #: EC-WS-0016

CC:

Job Title: Cold Weather Shutdown/Start-Up

References: Alcoa Safety Protocols

Purpose: Shut Down And Drain The System To Minimize Or Prevent Freeze Damage To The Equipment. This Operation Will Be Done 

Using Methods To Avoid Accidental Water Spills To The Process Or Storm Sewers And To Facilitate A Quick And Orderly Restart Of The 

Wet Scrubbers.

Equipment Required: Screw Driver, Channel Lock Pliers, Hose Cutting Tools

PPE: Safety Boots, Hard Hat, Safety Glasses, Ear Protection, Approved Respirator, Are Required For All Production Area Jobs.

JOB STEPS

PROPER WORK METHOD AND JOB ANALYSIS

(Equipment, Technology, Procedure)

HEALTH & SAFETY

HAZARDS ENVIRONMENT

fall to 30° F and remain at that level or below for several 

days. If a cold front is forecast for the weekend, this 

procedure will commence on Thursday afternoon.

position of the their 

head and back when 

entering and exiting 

the pan area so as 

not to cause injury to 

themselves.

Room by drawing out the 

dirty air. This air is directly 

released into the 

surrounding environment 

without treatment until the 

water systems are brought 

back on line.

3. Wet Scrubber 

Shutdown 

Process

a) In order to eliminate as much water from the system as 

possible, begin minimizing any process (P.U.D.) water 

additions as soon as the decision to shut down is made.

b) Good radio communication must be maintained between 

the Maintenance Crew, Scrubber Crew, and the Water 

Treatment Plant Operator during the shutdown to 

prevent an overflow discharge situation.

c) Switch to recycle water those scrubbers that are on 

Many of the valves, 

clamps and other 

items that need to 

be accessed are 

encased inside the 

steel “I” beam 

framework that 

supports the 
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 4:27 PM

A Emission Control

Intalco Works - Safety and Standard Operating Procedure

Approval: Pat Pollock 

Author: J. Goertz

Date: 8/25

Rev. #: 1

Doc. #: EC-WS-0016

CC:

Job Title: Cold Weather Shutdown/Start-Up

References: Alcoa Safety Protocols

Purpose: Shut Down And Drain The System To Minimize Or Prevent Freeze Damage To The Equipment. This Operation Will Be Done 

Using Methods To Avoid Accidental Water Spills To The Process Or Storm Sewers And To Facilitate A Quick And Orderly Restart Of The 

Wet Scrubbers.

Equipment Required: Screw Driver, Channel Lock Pliers, Hose Cutting Tools

PPE: Safety Boots, Hard Hat, Safety Glasses, Ear Protection, Approved Respirator, Are Required For All Production Area Jobs.

JOB STEPS

PROPER WORK METHOD AND JOB ANALYSIS

(Equipment, Technology, Procedure)

HEALTH & SAFETY

HAZARDS ENVIRONMENT

process (P.U.D.) water.

d) Start the shutdown by shutting down A-1 and A-2 first, C1 and C-2 next, then finishing up B-1 and B-2.

Contact the Water Treatment Plant Operator before the 

shutdown begins and the Operator will shut off the Recycle 

Line Valve to the appropriate Potline and recycle pumps, as 

they become no longer required. The recycle pumps will be 

drained as they are shut down. The manual makeup valve 

will be shut. The Wemco Level will be lowered to minimize 

water going to A-Sump and the cooling tower blow-down 

will be shut off.

individual Scrubber 

Units. A person has 

to be mindful of the 

position of the their 

head and back when 

entering and exiting 

the pan area so as 

not to cause injury to 

themselves.

4. Shutdown 

Sequence –

Wet 

Scrubbers

a) Shut off the recycle line valves on the south end of the 

scrubber deck and let the pumps cavitate to minimize 

the amount of water necessary to drain. Leave all 

scrubber fans running. Shutdown will require six (6) 

Many of the valves, 

clamps and other 

items that need to 

be accessed are 
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 4:27 PM

A Emission Control

Intalco Works - Safety and Standard Operating Procedure

Approval: Pat Pollock 

Author: J. Goertz

Date: 8/25

Rev. #: 1

Doc. #: EC-WS-0016

CC:

Job Title: Cold Weather Shutdown/Start-Up

References: Alcoa Safety Protocols

Purpose: Shut Down And Drain The System To Minimize Or Prevent Freeze Damage To The Equipment. This Operation Will Be Done 

Using Methods To Avoid Accidental Water Spills To The Process Or Storm Sewers And To Facilitate A Quick And Orderly Restart Of The 

Wet Scrubbers.

Equipment Required: Screw Driver, Channel Lock Pliers, Hose Cutting Tools

PPE: Safety Boots, Hard Hat, Safety Glasses, Ear Protection, Approved Respirator, Are Required For All Production Area Jobs.

JOB STEPS

PROPER WORK METHOD AND JOB ANALYSIS

(Equipment, Technology, Procedure)

HEALTH & SAFETY

HAZARDS ENVIRONMENT

people to shut down all of the scrubber pumps starting 

at the north end of both buildings. Then, as one 

reaches the south end, turn around and start draining 

scrubber tanks as much as the drain will allow, working 

one’s way north. At the same time, remove the recycle 

line drain plugs. (When one gets to door #2, one may 

not be able to drain as many scrubber tanks at a time as 

earlier because the drain will not accept that volume of 

water.)

b) Crack washdown valves on roofs after each filter 

washing during possible freezing weather. Check with 

Maintenance during shutdown to determine when 

Emission Control personnel can go through the building 

to open all lower valves at scrubber and tank washdown 

stations. (This step should normally be done starting in 

encased inside the 

steel “I” beam 

framework that 

supports the 

individual Scrubber 

Units. A person has 

to be mindful of the 

position of the their 

head and back when 

entering and exiting 

the pan area so as 

not to cause injury to 

themselves.
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 4:27 PM

A Emission Control

Intalco Works - Safety and Standard Operating Procedure

Approval: Pat Pollock 

Author: J. Goertz

Date: 8/25

Rev. #: 1

Doc. #: EC-WS-0016

CC:

Job Title: Cold Weather Shutdown/Start-Up

References: Alcoa Safety Protocols

Purpose: Shut Down And Drain The System To Minimize Or Prevent Freeze Damage To The Equipment. This Operation Will Be Done 

Using Methods To Avoid Accidental Water Spills To The Process Or Storm Sewers And To Facilitate A Quick And Orderly Restart Of The 

Wet Scrubbers.

Equipment Required: Screw Driver, Channel Lock Pliers, Hose Cutting Tools

PPE: Safety Boots, Hard Hat, Safety Glasses, Ear Protection, Approved Respirator, Are Required For All Production Area Jobs.

JOB STEPS

PROPER WORK METHOD AND JOB ANALYSIS

(Equipment, Technology, Procedure)

HEALTH & SAFETY

HAZARDS ENVIRONMENT

the fall and continuing through nonfreezing possibility 

which depending on weather patterns could be early 

spring)

c) The scrubber in the north end of each building and those 

at the doorways (or without heat ducts will start to freeze 

before the rest of the units.

5. Water 

Treatment 

Plant 

Shutdown 

(Primary & 

Secondary)

The primary objective of this step is to prevent any water 

from the Wet Scrubber and Water Treatment Plant 

System from escaping into the storm or process sewers, 

and to minimize or eliminate freeze damage to the 

system.

a. The purge volume during the shutdown operation should 

be monitored closely at the recycle tank to maximize 

evaporation and minimize purge water to the equalization 

tank (or to the Secondary Water Treatment Plant if full). 

Slippery surfaces and 

possible contact with 

hazardous materials. 

Use the proper PPE 

when possibilities 

such as this exist.
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 4:27 PM

A Emission Control

Intalco Works - Safety and Standard Operating Procedure

Approval: Pat Pollock 

Author: J. Goertz

Date: 8/25

Rev. #: 1

Doc. #: EC-WS-0016

CC:

Job Title: Cold Weather Shutdown/Start-Up

References: Alcoa Safety Protocols

Purpose: Shut Down And Drain The System To Minimize Or Prevent Freeze Damage To The Equipment. This Operation Will Be Done 

Using Methods To Avoid Accidental Water Spills To The Process Or Storm Sewers And To Facilitate A Quick And Orderly Restart Of The 

Wet Scrubbers.

Equipment Required: Screw Driver, Channel Lock Pliers, Hose Cutting Tools

PPE: Safety Boots, Hard Hat, Safety Glasses, Ear Protection, Approved Respirator, Are Required For All Production Area Jobs.

JOB STEPS

PROPER WORK METHOD AND JOB ANALYSIS

(Equipment, Technology, Procedure)

HEALTH & SAFETY

HAZARDS ENVIRONMENT

Before P.U.D. (Process Water) is shut off, drain and rinse 

Sodium Aluminate (SA) Recirculation Pumps at storage 

tank.

b. Shut off the recycle tank manual makeup valve. When 

the Process Water (P.U.D.) is shut off, open and drain 

both recycle makeup manual and auto valves.

c. Drain the recycle manifold from valve on east end of the 

manifold at the recycle tank. Also, open each recycle 

drain valve (north side of Water Treatment Plant).

d. Disconnect and DRAIN washdown hoses before the 

freeze hits.

e. Ensure the appropriate hoses are stored inside underflow 

buildings.

f. Close top valve on SA transfer line at storage tank.

g. If boiler is down, open steam valves and lay out steam 
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 4:27 PM

A Emission Control

Intalco Works - Safety and Standard Operating Procedure

Approval: Pat Pollock 

Author: J. Goertz

Date: 8/25

Rev. #: 1

Doc. #: EC-WS-0016

CC:

Job Title: Cold Weather Shutdown/Start-Up

References: Alcoa Safety Protocols

Purpose: Shut Down And Drain The System To Minimize Or Prevent Freeze Damage To The Equipment. This Operation Will Be Done 

Using Methods To Avoid Accidental Water Spills To The Process Or Storm Sewers And To Facilitate A Quick And Orderly Restart Of The 

Wet Scrubbers.

Equipment Required: Screw Driver, Channel Lock Pliers, Hose Cutting Tools

PPE: Safety Boots, Hard Hat, Safety Glasses, Ear Protection, Approved Respirator, Are Required For All Production Area Jobs.

JOB STEPS

PROPER WORK METHOD AND JOB ANALYSIS

(Equipment, Technology, Procedure)

HEALTH & SAFETY

HAZARDS ENVIRONMENT

hose to drain.

h. Crack open steam valve to SA mix tank to drain.

i. Open, flush and drain caustic pump valves.

j. Turn on steam trace valves on mezzanine deck and 

inside east underflow building. 

5. continued....

Water 

Treatment 

Plant 

Shutdown 

(Primary & 

Secondary)

k. Drain purge pump and lines (purge will be run as needed 

to maintain proper clarifier volume).

l. Monitor super sump to avoid overflow to storm sewer.

m. Purge (blowdown) will be necessary only if 

super sump requires it.

n. The recycle mud operation will end with the shut down of 

P.U.D. water.

o. All water and steam lines or hoses not in service will be 

drained as normal or, if possible, taken inside.

Slippery surfaces and 

possible contact with 

hazardous materials. 

Use the proper PPE 

when possibilities 

such as this exist.
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 4:27 PM

A Emission Control

Intalco Works - Safety and Standard Operating Procedure

Approval: Pat Pollock 

Author: J. Goertz

Date: 8/25

Rev. #: 1

Doc. #: EC-WS-0016

CC:

Job Title: Cold Weather Shutdown/Start-Up

References: Alcoa Safety Protocols

Purpose: Shut Down And Drain The System To Minimize Or Prevent Freeze Damage To The Equipment. This Operation Will Be Done 

Using Methods To Avoid Accidental Water Spills To The Process Or Storm Sewers And To Facilitate A Quick And Orderly Restart Of The 

Wet Scrubbers.

Equipment Required: Screw Driver, Channel Lock Pliers, Hose Cutting Tools

PPE: Safety Boots, Hard Hat, Safety Glasses, Ear Protection, Approved Respirator, Are Required For All Production Area Jobs.

JOB STEPS

PROPER WORK METHOD AND JOB ANALYSIS

(Equipment, Technology, Procedure)

HEALTH & SAFETY

HAZARDS ENVIRONMENT

6. Startup 

Sequence For 

Wet 

Scrubbers

a. Prior to supplying water to each building, close the main 

recycle valve at the south end and check the process 

(P.U.D.) water valve to ensure that the process (P.U.D.) 

water valve is closed.

b. Ambient temperature: above freezing for a minimum of 

six (6) hours prior to start-up.

c. Replace all recycle drain plugs and close the drain 

valves, including recycle valve outside south end of each 

building.

d. Close stand pipe valves (except each side of doorways) 

and remove all standpipe caps. Clamp all tank drains

e. Check for freeze damage (cracked valves, pushed apart 

couplings, etc.)

f. Fill tanks and start scrubbers from south to north in each 

building.

Many of the valves, 

clamps and other 

items that need to 

be accessed are 

encased inside the 

steel “I” beam 

framework that 

supports the 

individual Scrubber 

Units. A person has 

to be mindful of the 

position of their head 

and back when 

entering and exiting 

the pan area so as 

With the return of the water 

systems to online status 

the ability of the Wet 

Scrubbers to again capture 

air borne pollutants is 

restored.
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 4:27 PM

A Emission Control

Intalco Works - Safety and Standard Operating Procedure

Approval: Pat Pollock 

Author: J. Goertz

Date: 8/25

Rev. #: 1

Doc. #: EC-WS-0016

CC:

Job Title: Cold Weather Shutdown/Start-Up

References: Alcoa Safety Protocols

Purpose: Shut Down And Drain The System To Minimize Or Prevent Freeze Damage To The Equipment. This Operation Will Be Done 

Using Methods To Avoid Accidental Water Spills To The Process Or Storm Sewers And To Facilitate A Quick And Orderly Restart Of The 

Wet Scrubbers.

Equipment Required: Screw Driver, Channel Lock Pliers, Hose Cutting Tools

PPE: Safety Boots, Hard Hat, Safety Glasses, Ear Protection, Approved Respirator, Are Required For All Production Area Jobs.

JOB STEPS

PROPER WORK METHOD AND JOB ANALYSIS

(Equipment, Technology, Procedure)

HEALTH & SAFETY

HAZARDS ENVIRONMENT

g. Walk back through each building to check for leaks.

h. Keep in radio contact at all times with the Water 

Treatment Plant Operator and Maintenance Startup 

Crew.

i. Close all process (P.U.D.) water valves in scrubber pan 

on the west side of the scrubber tanks.

not to cause injury to 

them selves.
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 4:27 PM

Document Change History

REVISION 

DATE

NATURE OF REVISION DOCUMENT REVIEW PARTICIPANTS

ANY REVISION OF THIS DOCUMENT 

REQUIRES REVIEW AND APPROVAL BY 

ENVIRONMENTAL AFFAIRS

2/15/03 Date of Original Document Issuance

4/20/04 General Revision to add comments to Safety and 

Health Hazards

Maint Manager, Gen Supervisor, Supervisor, 

Reliability, Crew

6/28/03 Added Document Change History Table Maint. Manager, Main. Supervisor, Maint. 

Planner

9/9/04 Revision to Job Step #1 to include notification 

notice of Roof Scrubber Shut off.

Maint. Manager, Maint. Supervisor, Maint. 

Planner

Controlled documents must contain a Controlled Hardcopy Listing Table as shown below IF hardcopies are to 

be posted. This would include SPL’s and all other visuals on the floor that should be controlled. The 

electronic copy of the document has the below table. When it is to be printed for posting on the work site the 

controlled hardcopy listing table would be temporarily removed and replaced with a “Controlled Hardcopy” 

label.

Controlled Hardcopy Listing

CONTROL # OWNER LOCATION 

 3 LARRY BOUMA EC LEADMAN’S OFFICE
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 4:27 PM

SSOP Draft Approval/Review

Crew: Date:

Supervisor: Date:

Planner: Date:

Reliability: Date:

General Supervisor: Date:

Q:\Environmental Affairs\Members\E-3 Air\SSM Plan\Temp\ssmp_Potlines_current_3.doc

End of SSM

Emission Control Crew

Larry Bouma

NA

Max G. Liese

Don Van Every

4/20/04

4/20/04

NA

8/25/04

8/31/04