Potline Startup, Shutdown and Malfunction Plan Page 1 of 8

Alcoa – Mt. Holly

TV-0420-0015

Condition: Start-Up of Potline

To prevent excess or uncontrolled emissions from the Potline, this startup plan must be followed 

for all startups. In the event that a start-up of a Potline served by this emission control system 

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

process gas flow or alumina flow, the following Start-Up plan must be re-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(s) of aluminum 

reduction cells that is serviced by a common emission control device. The start-up begins when 

the first idled reduction cell is energized. The start-up concludes no more than 180 days 

following start-up. Appropriate parametric ranges during a start-up are those typical ranges that 

have previously been established for this emission control device. 

1. The Operator(s) is to assure that prior to start-up of the Potline that the emission control 

system is on line and operating within normal parametric limits.

2. In the event of operation outside of acceptable parametric limits, the Operator is to assure 

that the emission control system is still on line. If this is not the case, a shut down of the 

Potline is to be initiated.

3. The Start-Up is to be logged. Include the time, date, duration of event, extraordinary actions 

taken beyond the scope of this plan, and initials or a signature. Records of the start-up are to 

be retained for five (5) years. Should non-conformance with an applicable requirement 

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

Department.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.
Potline Startup, Shutdown and Malfunction Plan Page 2 of 8

Alcoa – Mt. Holly

TV-0420-0015

Condition: Shut-Down of Potline

To prevent excess or uncontrolled emissions from the Potline, this shutdown plan must be 

followed for all shutdowns. In the event that a shut-down of Potlines served by this emission 

control system creates or leads to a situation that causes operation outside of appropriate 

parametric ranges for process gas flow or alumina flow, the following Shut-Down plan must be 

re-initiated within one hour of first becoming aware of the situation.

A shut-down is defined as the process of intentional shut down of the Potline for a period of an 

hour or longer. The shut-down process includes the stoppage of power to the Potline. The shutdown begins when operations are intentionally shut down for a period of an hour or more. The 

shut-down concludes when the components of the system have been secured in a shutdown mode 

or a startup is initiated. The scrubber shall run until the Potline shutdown has been secured. 

Appropriate limits for parametric ranges during a shut-down are those typical ranges that have 

previously been established for this emission control device. 

1. In the event of operation outside of approved parametric limits the Operator is to assure that 

the emission control system is still on line. If this is not the case, the shut down of bake oven 

is to proceed immediately and efforts to re-start the emission control system are to be 

initiated.

2. The shut-down concludes when the components of the system have been secured in a 

shutdown mode. The emission control system may be shut down after this has occurred.

 

3. The Shut-Down is to be logged. Include the time, date, duration of event, extraordinary 

actions taken beyond the scope of this plan, and initials or a signature. Records of the shutdown are to be retained for five (5) years. Should non-conformance with an applicable 

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

Environmental Department.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.
Potline Startup, Shutdown and Malfunction Plan Page 3 of 8

Alcoa – Mt. Holly

TV-0420-0015

Condition: Catastrophic Failure of Fume Control Equipment

In the event of catastrophic failure of fume control equipment or components in this emission 

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

within one hour of first becoming aware of a malfunction

Examples of catastrophic failure include, but are not limited to; collapse of a Dry Injection Fume 

Control Device or inlet duct, a direct lightning strike, a loss of electrical power, a hurricane, an 

earthquake, a tornado 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 equipment on the unit is down 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 is to restart all operational equipment, notify 

appropriate maintenance (for necessary repairs), 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, efficient, and timely manner.

4. The system operator or proxy will be responsible for logging the time, date, duration and 

cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and 

initials or a signature. Maintenance personnel will be responsible for making appropriate 

entries into any maintenance logs.

5. Records of the malfunction and maintenance activity are to be retained for five (5) years. 

Should non-conformance with an applicable requirement occur, it is to be entered into the 

semi-annual reporting period log kept by the Environmental Department.
Potline Startup, Shutdown and Malfunction Plan Page 4 of 8

Alcoa – Mt. Holly

TV-0420-0015

Condition: Visible Emissions – Dusting Stack(s)

In the event that emissions outside the normal operating range are visibly being emitted from the 

exhaust(s) of the emission control system (device) the following malfunction and corrective 

action plan must be implemented within one hour of the initial observation of the malfunction.

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

emissions observed by the operator (or reported to him) from the stack on the fume control 

system(s).

1. The operator is to report the 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 confirmed reported 

emissions or has initiated this plan.

2. Following this initial response, the operator is to initiate corrective action within one hour by 

having 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, efficient, and timely manner.

4. The system operator will be responsible for logging the time, date, duration and cause of the 

malfunction, extraordinary actions taken beyond the scope of this plan, and initials or a 

signature in the visible emission log. If required, maintenance personnel will be responsible 

for making appropriate entries into any maintenance logs.

5. Records of the event and maintenance activity are to be retained for five (5) years. Should 

non-conformance with an applicable requirement occur, it is to be entered into the semiannual reporting period log kept by the Environmental Department.
Potline Startup, Shutdown and Malfunction Plan Page 5 of 8

Alcoa – Mt. Holly

TV-0420-0015

Condition: Loss of Parametric Monitoring – Fresh Alumina Feeder Signal

In the event of a loss of the fresh alumina feeder signal(s) for the emission control systems, the 

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

becoming aware of a malfunction.

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

programmable logic controller (PLC) and Wonderware (Data logging) central monitoring system 

for more than one (1) hours in any twenty-four (24) hour period. This also includes loss of a 

measurement device (signal) component that results in a daily cumulative fresh alumina feeder 

tph (tons per hour) parametric that is below established limits of 7.0 tons per hour.

1. The operator is to confirm the system status, noting if the Control room PLC is off line or if 

the Wonderware (data logging) central monitoring system is not recording data. 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 contact outside contractor or restart the PLC or Wonderware system.

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, efficient, and timely manner.

4. The system operator or proxy will be responsible for logging the time, date, duration and 

cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and 

initials or a signature. Maintenance personnel will be responsible for making appropriate 

entries into any maintenance logs.

5. Records of the malfunction and maintenance activity are to be retained for five (5) years. 

Should non-conformance with an applicable requirement occur, it is to be entered into the 

semi-annual reporting period log, kept by the Environmental Department.
Potline Startup, Shutdown and Malfunction Plan Page 6 of 8

Alcoa – Mt. Holly

TV-0420-0015

Condition: Loss of Parametric Monitoring – Fan Amperage Signal

In the event of a loss of the fan amperage signal for the emission control systems, the following 

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

of a malfunction.

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

programmable logic controller (PLC) and Wonderware (Data logging) central monitoring system 

for more than one (1) hour in any twenty-four (24) hour period. This also includes loss of a 

measurement device (signal) component that results in a daily cumulative fan amperage-hour 

parametric that is below established limits of 425 amps each (for 4 fan operation) or 465 amps 

for 3 fan operation. 

1. The operator is to confirm the system status, noting if the Control room PLC is off line or if 

the Wonderware (data logging) central monitoring system is not recording data. 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 restart the PLC or Wonderware system.

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, efficient, and timely manner.

4. The system operator or proxy will be responsible for logging the time, date, duration and 

cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and 

initials or a signature. Maintenance personnel will be responsible for making appropriate 

entries into any maintenance logs.

5. Records of the malfunction and maintenance activity are to be retained for five (5) years. 

Should non-conformance with an applicable requirement occur, it is to be entered into the 

semi-annual reporting period log, kept by the Environmental Department.
Potline Startup, Shutdown and Malfunction Plan Page 7 of 8

Alcoa – Mt. Holly

TV-0420-0015

Condition: Low Flow of Alumina 

In the event of low flow of alumina through this emission control system (less than 7.0 tons per 

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

first becoming aware of a malfunction.

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

the primary air gravity conveyor (air slide) or one of its components, (such as the media cloth 

membrane or the primary, air float, blowers), excessive downtime and /or failure (malfunction) 

of air lift material transfer units, fresh alumina storage tank low (or empty) levels and excessive 

(or full) reacted alumina storage tanks. Also included are reductions in alumina flow due to 

excessive compartments out of service due to various reasons. 

1. The operator is to confirm the system status and/or problems with air float blowers, air lift 

material transfer (removal) systems as well as confirm levels in the fresh and reacted storage 

tanks. The operator is to then 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 and notify 

proper appropriate personnel to initiate repairs and/or conditions. If only the feeder is faulted 

utilize the bypass to re-establish feed until the feeder can be repaired.

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).

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, efficient, and timely manner.

4. The system operator or proxy will be responsible for logging the time, date, duration and 

cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and 

initials or a signature. Maintenance personnel will be responsible for making appropriate 

entries into any maintenance logs.

5. Records of the malfunction and maintenance activity are to be retained for five (5) years. 

Should non-conformance with an applicable requirement occur, it is to be entered into the 

semi-annual reporting period log kept by the Environmental Department.
Potline Startup, Shutdown and Malfunction Plan Page 8 of 8

Alcoa – Mt. Holly

TV-0420-0015

Condition: Low Flow of Process Gas

In the event of low flow of process gas (low air flow) through this emission control system as 

indicated by a daily cumulative fan amperage-hour parametric that is below established limits of 

425 amps each (for 4 fan operation) or 465 amps (for 3 fan operation), 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; a failure or malfunction of a fan, 

an unexpected loss of electrical power and/or problems with multiple compartment downtime 

which reduce the static pressure parametric value below established limits. 

1. The operator is to confirm the system status, noting if compartments (cells) are either off line 

or otherwise impaired. The amperage set point on the main fan controller needs to be 

checked to insure proper setting as well as the operating condition of the fan motor. Operator 

needs to insure that compartment (cells) differential pressures are within control. 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).

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, efficient, and timely manner.

4. The system operator or proxy will be responsible for logging the time, date, duration and 

cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and 

initials or a signature. Maintenance personnel will be responsible for making appropriate 

entries into any maintenance logs.

5. Records of the malfunction and maintenance activity are to be retained for five (5) years. 

Should non-conformance with an applicable requirement occur, it is to be entered into the 

semi-annual reporting period log kept by the Environmental Department.