National Emission Standards for Hazardous Air 

Pollutants for Primary Aluminum Reduction Plants

Alcoa

Wenatchee Works

GREEN ANODE PLANT PRIMARY EMISSION CONTROL 

SYSTEM

Start up, Shut Down, and Malfunction Plan

Prepared by:

Alcoa Inc.

6200 Malaga – Alcoa Hwy.

Malaga, WA 98828

Revision 3

June 21, 2006
TABLE OF CONTENTS

PAGE

TABLE OF CONTENTS i

1.0 INTRODUCTION 1

2.0 START UP PLAN 1

3.0 SHUT DOWN PLAN 1

3.5 EXTENTED SHUTDOWN PLAN 2 

4.0 CORRECTIVE ACTION PLAN 2

LOW AIR FLOW

LOW ALUMINA FLOW

LOSS OF PARAMETRIC MONITORING 3

5.0 MALFUNCTION PLAN 3

CATASTROPHIC FAILURE OF FUME CONTROL EQUIPMENT 

6.0 VISIBLE EMISSION PLAN 4

FLOW CHART APPENDIX A
 WENATCHEE WORKS Page 1 REVISED FEBRUARY 16, 2000

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

1.0 INTRODUCTION

This Startup, Shutdown, Malfunction (SSM) Plan meets the requirements of the Primary 

Aluminum NESHAP. This plan contains procedures to be used during periods of startup, 

shutdown, and malfunction as well as procedures for corrective action. This plan will be made 

available to the permitting authority upon request. 

2.0 STARTUP PLAN

A startup is defined as the process of heating green anode mix above the softening point of the 

binder pitch. The startup begins when the mix exceeds the softening point of the pitch binder and 

concludes when anodes are formed. The green anode plant is a non-continuous process and 

startups and shutdowns may occur on a regular basis, often several times a day.

This plan is to be followed for the startup of the green anode plant’s primary control device. The 

semi-annual report will note only those instances the plan is not followed. If this plan was 

not followed, the event is to be reported immediately to the plant’s environmental department. 

Within 2 days the environmental department will call the agency followed by a notification letter 

posted within 7 days. If necessary, revisions to this plan must be submitted within 45 days of the 

event. Revisions to this plan must be retained for 5 years. 

1. The Operator is to ensure that prior to startup of the green anode plant, the primary control 

device is operating with proper airflow and coke flow.

2. The Operator will commence startup.

3. The Operator is responsible for logging exceptions to the startup on the SSM log.

4. Records of startup exceptions are to retained for five (5) years. 

3.0 SHUTDOWN PLAN

A shutdown is defined as the process of initiating the end of anode mixing, transfer, and anode 

forming. The shutdown begins when adding new mix to the mixers is halted and concludes when 

all mix has been formed into anodes or has cooled below the softening point of the binder pitch. 

The paste plant is a non-continuous process and shutdowns may occur on a regular basis, often 

several times a day. 

This plan is to be followed for the shutdown of the green anode plant. The semi-annual report 

will note only those instances the plan is not followed. If this plan was not followed, the event 

is to be reported immediately to the plant’s environmental department. Within 2 days the 

environmental department will call the agency followed by a notification letter posted within 7 days. 

If necessary, revisions to this plan must be submitted within 45 days of the event. Revisions to 

this plan must be retained for 5 years. 

1. The Operator will ensure proper coke flow and airflow during the shutdown.

2. The Operator may shut down the control device when the shutdown concludes.
 WENATCHEE WORKS Page 2 REVISED FEBRUARY 16, 2000

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

3. If, during a normal shutdown, there is a failure of the anode pusher to clear the formed anode 

from the former, then the Operator may shut down the control device one hour after the 

anode has formed and the mixers and conveyors have also been emptied and still for an 

hour. Under this scenario maintenance personnel are responsible for making appropriate 

entry into the maintenance log.

4. The Operator is responsible for logging exceptions to the shutdown on the SSM log. 

5. Records of the exceptions are to be retained for five (5) years. 

3.5 EXTENDED SHUTDOWN PLAN

An extended shutdown is defined as the process of initiating the end of anode mixing, transfer, 

and anode forming for an indefinite period of time that will require removing pitch and coke from 

storage tanks and conveying systems. The shutdown begins one day prior to halting the process 

of forming anodes and concludes when pitch and coke storage tanks, hoppers, all conveying 

systems are empty and all mix has been formed into anodes or has cooled below the softening 

point of the binder pitch. 

This plan is to be followed for an extended shutdown of the green anode plant. The semi-annual 

report will note only those instances the plan is not followed. If this plan was not followed, 

the event is to be reported immediately to the plant’s environmental department. Within 2 days 

the environmental department will call the agency followed by a notification letter posted within 7 

days. If necessary, revisions to this plan must be submitted within 45 days of the event. 

Revisions to this plan must be retained for 5 years. 

1. The operator will one day prior to / or the last day before an extended shutdown reduce 

inventory in 7-ton coke injection supply tank and Dry Coke Scrubber hopper to a minimum 

and maintain only enough coke to feed Dry Coke Scrubber injection points.

2. The Operator will ensure proper airflow during most of the shutdown. Airflow will only be 

reduced as final filter bag cleaning is preformed as close to last mixer load possible. 

3. Coke feed to the injector system will be stopped prior to shutdown. However, every effort 

possible will be taken by Green Mill personnel to insure coke and pitch inventories are 

reduced in a manor to minimize the time required to complete forming after injection coke 

has stopped.

6. The operator will record time injection hopper has emptied or coke injection feeder has been 

shut-off, on the SSM Log.

5. At no time during the shutdown, or purging of liquid pitch lines with nitrogen will pitch be 

added to mixers without adequate coke. 

 

7. The Operator may shut down the control device when the shutdown concludes and note time 

on SSM Log.

8. The Operator is responsible for logging exceptions to the shutdown on the SSM log. 

9. Records of the exceptions are to be retained for five (5) years. 
 WENATCHEE WORKS Page 3 REVISED FEBRUARY 16, 2000

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

4.0 CORRECTIVE ACTION PLAN

4.1 Low Air Flow

Low air flow is defined as air flow lower than the parametric limit of 75% output on the fan. It is 

determined by comparison of the average hourly % output of the fan with the hourly limit for 

compliance. Failure of the parameter to meet the limit for compliance is an exceedance. The 

following Corrective Action Plan must be initiated within one hour of first becoming aware of the 

exceedance. The failure to initiate this Corrective Action Plan within an hour will result in a 

violation. The 7th exceedance of a coke scrubber fume control device parametric in the semiannual reporting period will result in a violation. Both exceedances and violations must be 

reported on the semi-annual report.

1. The Operator is to log the time that he/she first became aware of the exceedance and the 

time at which he/she initiated the corrective action plan. 

2. The Operator is to confirm the system status and initiate a green anode plant shutdown. 

3. The Operator is to notify appropriate maintenance personnel or restart the component(s). 

4. Personnel responding are to make repair(s), equipment replacement(s), or process change(s) 

to remedy the situation in a safe, efficient, and timely manner.

5. The Operator is responsible for logging the exceedance on the SSM log. This will include 

logging the time, date, duration, cause of the exceedance, any actions taken beyond the 

scope of this plan, and initials or signature.

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

7. Records of the exceedance are to be retained for five (5) years. 

4.2 Low Coke Flow

Low Coke Flow is defined as a coke flow rate lower than the parametric limit of 45% RVF output. 

It is determined by comparison of the average hourly coke flow to the hourly limit for compliance. 

Failure of the parameter to meet the limit for compliance is an exceedance. The following 

Corrective Action Plan must be initiated within one hour of first becoming aware of the 

exceedance. The failure to initiate this Corrective Action plan within an hour will result in a 

violation. The 7th exceedance of a coke scrubber fume control device parametric in the semiannual reporting period will result in a violation. Both exceedances and violations must be 

reported on the semi-annual report.

1. The Operator is to log the time that he/she first became aware of the exceedance and the 

time at which he/she initiated the corrective action plan. 

2. The Operator is to confirm the system status and initiate a green anode plant shutdown.

3. The Operator is to notify appropriate maintenance personnel or restart the component(s). 
 WENATCHEE WORKS Page 4 REVISED FEBRUARY 16, 2000

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

4. Personnel responding are to make repair(s), equipment replacement(s), or process change(s) 

to remedy the situation in a safe, efficient, and timely manner.

5. The Operator is responsible for logging the exceedance on the SSM log. This will include 

logging the time, date, duration, cause of the exceedance, any actions taken beyond the 

scope of this plan, and initials or signature.

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

logs.

7. Records of the exceedance are to be retained for five (5) years. 

4.3 Loss of Parametric Monitoring for Air and/or Coke Flow

In the event of the loss of signal for Fan output or RVF output for the coke scrubber, the following 

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

of the occurrence.

Examples of loss of signal include, but are not limited to, loss of monitoring device, PLC or power 

outage.

1. The operator is to log the time he/she first became aware of the loss of signal and the time at 

which he/she initiated corrective action.

2. The operator is to confirm system status.

3. The operator is to notify appropriate maintenance and/or engineering personnel to make 

necessary repairs.

4. Personnel responding are to make repairs, equipment replacement or restart PLC control 

devices to remedy the situation in a safe, efficient and timely manner.

5. The operator is responsible for logging the time, date, duration and cause of the loss of signal 

as well as any extraordinary actions taken not included in this corrective action plan. 

6. Maintenance personnel are responsible for making appropriate entries into the maintenance 

logs.

7. Records of the Malfunction and maintenance activity are to be retained for five (5) years.
 WENATCHEE WORKS Page 5 REVISED FEBRUARY 16, 2000

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

5.0 MALFUNCTION PLAN

5.1 Catastrophic Failure of Fume Control Equipment

A catastrophic failure of the fume control equipment is considered a malfunction. This plan is to 

be followed for a catastrophic failure of the fume control device. The semi-annual report will 

note only those instances the plan is not followed. If this plan was not followed, the event is 

to be reported immediately to the plant’s environmental department. Within 2 days, the 

environmental department will call the agency followed by a notification letter posted within 7 days. 

If necessary, revisions to this plan must be submitted within 45 days of the event. Revisions to 

this plan must be retained for 5 years. 

Examples of catastrophic failure include, but are not limited to; collapse of an inlet duct, a direct 

lightning strike, a loss of electrical power, 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 is 

to confirm the system status, noting which equipment is 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. 

2. The Operator is to notify appropriate maintenance, engineering and support personnel. 

Those 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.

3. The Operator is responsible for logging the malfunction on the SSM log. This will include 

logging the time, date, duration, and cause of the malfunction, any actions taken beyond the 

scope of this plan, and initials or signature.

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

logs.

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

6.0 VISIBLE EMISSION PLAN

Visible emissions are defined as stack dusting that indicates filter bag problems. The following 

Visible Emission Plan must begin within one hour of noticing visible emissions. The failure 

to initiate this plan within an hour will result in a violation. Violations must be reported on the 

semi-annual report.

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.

2. The Operator is to log the time that he/she first noticed or was notified of the condition and 

also log the time which he/she initiated this plan. 

3. The Operator is to shut down the control device and green anode plant to make repairs.

4. Personnel responding to the malfunction are to make repair(s) or remedy the situation in a 

safe, efficient, and timely manner.
 WENATCHEE WORKS Page 6 REVISED FEBRUARY 16, 2000

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

5. The Operator is responsible for logging the corrective action on the SSM log. This will include 

logging the time, date, duration, any actions taken beyond the scope of this plan, and initials 

or signature.

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

logs.

7. Records of the visible emissions are to be retained for five (5) years.
APPENDIX A

Flowchart

ξ63.850 Notification, reporting, and record keeping requirements. 

Start corrective

Action within

one hour

Visible

Emissions

NO

Document

In malfunction log

Violation:

Notify environmental 

immediately

Parametrics Over

Limit?

(Exceedance)

SOPs

Start 

corrective

Action within

one hour

YES

Exceedance:

Document in 

malfunction log/ notify 

environmental

7th within

six Months?

Startup, Shutdown,

Malfunction and

Corrective Action

Plans

YES

Report to environmental 

within

two days.

Letter to EPA within

7 days.

Revise & submit

plan in 45 days

NO

Recordkeeping

YES

YES

NO

Violation:

Notify environmental 

immediately

Violation:

Notify environmental 

immediately

Followed

Plan?

Normal 

startup/shutdown

Malfunction

Document

In malfunction log

No Action necessary
Revision Summary

Note: 40 CFR Part 63‚ Section 850‚ Paragraph (c) states that Ecology may review this plan upon request.

Approval must be obtained by Ecology before any significant changes implemented. 40 CFR 

63.6(e)(3)(viii) requires all changes be made in 45 days were the plan does not adequately address an 

event that meets the characteristic of a malfunction. 

Revision Date Nature of Revision Document Review Participants

Rev. 0: Original Issuance

Rev. 1 

Mar. 4, 2003 Rev 2

June 21, 2006 Rev 3 KAK – Added provisions for failure of anode 

pusher, Section 3. Added Revision 

Summary.