# 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 Ma laga

– Alcoa Hwy.

Malaga, WA 98828

Revision 3

June 21, 2006

## T ABLE OF 

## C ONTENTS

PAGE

TABLE OF CONTENTS i

1.0 INTRODUCTION 1

2.0 START UP PLAN 1

3.0 SHUT DOWN PLAN 1

3.5 EXTENTED SHUTDO WN PLAN 2

4.0 CORRECTIVE ACTI ON PLAN 2

LOW AIR FLOW

LOW ALUMINA FLOW

LOSS OF PARAMETRIC M ONITORING 3

5.0 MALFUNCTION PLA N 3

CATASTROPHIC FAILURE OF FUME CONTROL EQUI PMENT

6

. 0 VISIBLE EMISS ION PLAN 4

FLOW CHART APPENDIX AW ENATCHEE W ORKS Page 1

R EVISED F EBRUARY 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 th e

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 immed iately 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. R evisions 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 shutdown s 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

i s 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.W ENATCHEE W ORKS Page 2

R EVISED F EBRUARY 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 shutdow n, 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 thi s 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 syst ems. 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 th e 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 t his 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 in jector 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 sto pped.

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 adeq uate 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 f ive (5) years.W ENATCHEE W ORKS Page 3

R EVISED F EBRUARY 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 7 th exceedance of a coke scrubber fume control device parametric in the semi

annual reporting period will result in a violation. Both exceedances and violations must be

reported on the semi

- annua l 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 c omparison 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 th e

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

violation. The 7 th exceedance of a coke scrubber fume control device parametric in the semi

annual reporting period will result in a violation. Both exceed ances 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 st atus and initiate a green anode plant shutdown.

3

. The Operator is to notify appropriate maintenance personnel or restart the component(s).W ENATCHEE W ORKS Page 4

R EVISED F EBRUARY 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 limite d 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 oper ator 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 th e maintenance

logs.

7

. Records of the Malfunction and maintenance activity are to be retained for five (5) years.W ENATCHEE W ORKS Page 5

R EVISED F EBRUARY 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 consid ered 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. Revisi ons 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 co ndition 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), equipmen t 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 malfuncti on, 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 VISI BLE 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 r esult 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 rep air(s) or remedy the situation in a

safe, efficient, and timely manner.W ENATCHEE W ORKS Page 6

R EVISED F EBRUARY 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

ξ 63.850 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

7 th 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 environmenta l

immediately

Foll owed

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 ob tained 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 Revi sion 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.