# 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 1 February 1, 2011

, 2005Alcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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

Malfunct ion 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 Formatted: TOC 2

Formatted: Font: Not Bold, Complex Script

Font: Times New Roman, Not BoldAlcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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

C atastrophic 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 Formatted: Font: Not Bold, Complex Script

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Font: Times New Roman, Not BoldAlcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 po tline 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 po llution control equipment, process equipment, or a process to operate in a normal or usual manner. Failures that are caused in part by poor maintenance or careless operation are not malfunctions.”

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

Ensure that, at all times, the owner or operator operates and maintains each affected source, including associated air pollution control and monitoring equipment, in a manner which satisfies the general duty to minimize emissions established by

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

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

Reduce the reporting bu rden 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

vio lation.Alcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 

### 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 eac h 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, not ify 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 mo nitoring 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 (inclu ding 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 res ults 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, incl uding relevant data from production and maintenance, by

the 7 th 

### day of each quarter to the Environmental Department for preparation of quarterly reports. Keep all SSM plan

- required data in the Emission Control Supervisor’s office

— send only copies or relev ant reports and/or summaries to the Environmental Department.Alcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 Page: 3 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 

### 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 Departmen t 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 o f any exceedance

− Corrective actions taken

− Preventative measures taken

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

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 Page: 4 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 

### 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 wate r flow (to the wet scrubbers) the following Start

Up plan 

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

A start

- up or re

- start is defined as the process of 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

po ts connected to an op erational 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 t hat 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. (T his ratio of a minimum of 20 for A line Formatted: Heading 2

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...Alcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 Page: 5 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 

### 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

- start ed.)

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 follow s the addition of liquid bath to the last re

- start pot and may overlap into a pe riod 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 o perating report submitted for the month in question.

**Fume Treatment Ce n**  **ter 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 facilit y’s Parametric Monitoring Plan.

**Pot Operation Requirements** 

1 ) Prior to energizing a pot the following activit ies 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 fu me take

- off ducts in the superstructure of the pot must be cleaned as required.

2 ) Potline start up 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. Formatted: No bullets or numbering

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Formatted: Complex Script Font: 10 ptAlcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 act ivities 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

Enviro nmental Department and be reported in the monthly air operating report submitted for the month in question. Formatted: No underline, Font color: Auto, Complex Script Font: 10 pt

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color: AutoAlcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 system s (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 becom ing 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 cont rol 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 p arametric 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 m aintained. 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 second ary 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 D epartment 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 Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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

4:27 PM 

### Malfunction and Corrective Action Plans

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

Low Air 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 Pro cess 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 dete cted. 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 RecordsAlcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 fl ow 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 operationa l 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 notice d or reported and also log the time at which he/she first began to respond to check the system status.

2 ) Following this initial response, the operator or proxy is to notify appropriate maintenance personnel and/or initiate a maintenance work order, or restar t the 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 wil l 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 excee dence
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 Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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

4:27 PM Air Flow Operational Limits f or “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 23,500Alcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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) Operation al 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 23,600Alcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 Opera tional Limits f or “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 20,600Alcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 du e 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 op erator 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) year s. 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 Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 gener ates 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 Po t 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 fir st 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 Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 i n 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 fr eeze 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 Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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) in clude, 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 includ ing, 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 pro xy 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 exceede nce 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 Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 l oss 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/s he 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 p ower.

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

- an nual 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 Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 ha zards 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 ) Reco rds 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 Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 w et r oof scrubber and wastewater treatment operations. In the event of a su dden 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 n orth 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 (re**  **fer 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 goo d 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 a rms of the north ern 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 Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 Page: 20 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 

### Revision Summary

Note: 40 CFR Part 63‚ Section 850‚ Paragraph (c) states that Ecology may review this p lan 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 Ove n 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 Formatted

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...Alcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 S tart up,**  **S hut down,**  **M alfunction**  **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 Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 yo ur supervisor is al so requested. Air Flow

Fresh Ore Flow

Water Flow

Abnormal Visible Emission

Loss of Parametric Monitoring Signals

Catastrophic Failure of Emission Control Equipment

Cold Weather ShutdownAlcoa Intalco Works Potlines Startup/Shutdown/Malfunction Plan

Department: Environmental Approval: Jim Schon Kathryn

Mitchell

Issue Date: 10.08.88

Rev. No.: 2 3

Rev. Date: 06 0 2 .01. 05 11 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 ? VIOLATION No 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 preve nt 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 p rocess (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

neces sary 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 proces s (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, th e 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 af ternoon. position of the their

head and back when entering a nd 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 Maintenan ce 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 , C

1 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 t o
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

w ashing 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 s tarting 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

en tering 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 re st 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 equa lization tank (or to the Secondary Water Treatment Plant if full). Slippery surfaces and possible contact with

hazardous materials. Use the proper PPE when possibili ties

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 valv e 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 so uth 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 PART ICIPANTS

ANY REVISION OF THIS DOCUMENT

REQUIRES REVIEW AND APPROVAL BY

ENVIRONMENTAL AFFAIR S

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. Mana ger, 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 l isting 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