Green Mill Startup, Shutdown and Malfunction Plan Page 1 of 9 Alcoa

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### Condition: Start

- Up of Green Mill To prevent excess or uncontrolled emissions from the Green Mill, this startup plan must be followed for all startups. In the event that a start

- up of green anode processing equipment 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 coke flow, the following Start

- Up plan must be re

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

A start

- up is defi ned as the process of heating green anode mixing, green mix transfer and green anode forming equipment to a temperature above the softening point of the pitch binder to produce green anodes

. The start

- up begins when the emission control system is started. The
start

- up concludes when green anode production begins. Appropriate limits for 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 pr ior to Green Mill start

- up 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 o n line. If this is not the case, a shut down of green anode mixing, green mix transfer and green anode forming equipment is to be initiated.

3

. The Start

- Up concludes when production of green anodes begins.

4

. 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 clock number. Records of the start

- up are to be retained for five (5) years.

Note: All revisions to this plan are to be retained for five (5) years from t heir date of issue.Green Mill Startup, Shutdown and Malfunction Plan Page 2 of 9 Alcoa

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### Condition: Shut

- Down of Green Mill To prevent excess or uncontrolled emissions from the Green Mill, this shutdown plan must be followed for all shutdowns. In the event that a shut

- down of green anode processing equipment served by th is emission control system creates or leads to a situation that causes operation outside of appropriate parametric ranges for process gas flow or coke flow, the following Shut

Down plan must be re

- initiated within one hour of first becoming aware of the si tuation.

A shut

- down is defined as the process of intentional shut down of green anode mixing, mix transfer and green anode forming equipment and emission control equipment. The shut

- down process include reductions in temperature below the softening poi nt of the pitch binder. The shut

- down begins when pitch flow to the mixer stops, ending the production of green anode paste. The shut

- down concludes when the components of the system have cooled below the softening point temperature of the pitch binder, a nd the emission control device is shut down. 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 param etric 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 green anode; mixing, mix transfer, and forming equipment is to proceed immediately and efforts to

re

- start the emission con trol system are to be initiated.

2

. The Shut

- Down concludes when the components of the system have cooled below the softening point temperature of the pitch binder. The emission control system may be shut down after this has occurred.

3

. The Shut

- Down is to b e logged. Include the time, date, duration of event, extraordinary actions taken beyond the scope of this plan, and initials or clock number signature. Records of the shut

- down are to be retained for five (5) years.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.Green Mill Startup, Shutdown and Malfunction Plan Page 3 of 9 Alcoa

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### Condition: Low Flow of Process Gas (Loss of Fan Draft) In the event of low flow of process gas (a.k.a.

- low air flow) through this emission control system the following malfunction and correctiv e 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 and reductions in flow due to unplanned outages that generates a fan draft

- hours per day parametric that is below the established limit of 2.5" wg.

1

. The operator is to confirm the system status, noting which system components 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 and Environmental 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 an y 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 Environm ental Department.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.Green Mill Startup, Shutdown and Malfunction Plan Page 4 of 9 Alcoa

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### Condition: Low Flow of Coke In the event of low flow of coke through this emission control system the following malfunction and correctiv e 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 failure of the primary feeder or one of its components or the primary blower that genera tes a rotary vane feeder

- hours per day (RVF

- Hr/Day) parametric that is below the established limit of 1.8 tons per hour.

1

. The operator is to confirm the system status, verifying the no feed or reduced feed condition. The operator is to log the time that t he 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 and Environmental 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 opera tor 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

en tries 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.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.Green Mill Startup, Shutdown and Malfunction Plan Page 5 of 9 Alcoa

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### Condition: Loss of Parametric Monitoring

- Fan Draft In the event of loss of fan draft signal for this emission control sys tem 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, or remote monitoring system for more than six (6) hours in any twenty

- four (24) hour period or loss of a measurement device component that results in a fan draft

- hours per day parametric that is below the established limit of 2.5"wg.

1

. The operator or tech nician is to confirm the system status, noting which PLC is off line or which compartments have suffered signal loss. The operator is to log the time that the condition was first noticed or reported and also log the time at which he/she first began to

res pond to check the system status.

2

. Following this initial response, the operator or proxy is to notify appropriate Maintenance and Environmental personnel and/or initiate a maintenance work order, or restart the PLC.

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, extr aordinary 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.

Note: All revisions to this plan are to be retained for five (5) years f rom their date of issue.Green Mill Startup, Shutdown and Malfunction Plan Page 6 of 9 Alcoa

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### Condition: Loss of Parametric Monitoring

- Green Mill On/Off Status In the event of loss of on/off signal(s) for the Green Mill the following malfunction and corrective action plan must be initiated within one hour of first beco ming aware of a malfunction.

Examples of loss of signal include, but are not limited to; unexpected failure of the programmable logic controller, PLC or remote monitoring system for more than six (6) hours in any twenty

- four (24) hour period or loss of a measurement device component that results in a loss of Green Mill start and stop times that is below the established limits.

1

. The operator or technician is to confirm the system status, noting which PLC is off line or which compartments have suffered signa l loss. The operator is to log the time that the condition was first noticed or reported and also log the time at which he/she first began to respond to check the system status.

2

. Following this initial response, the operator or proxy is to notify appropri ate Maintenance and Environmental personnel and/or initiate a maintenance work order, or restart the PLC.

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, effic ient, 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 wil l 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 th e 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.Green Mill Startup, Shutdown and Malfunction Plan Page 7 of 9 Alcoa

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### Condition: Loss of Parametric Monitoring

- Rotary Vane Feeder In the event of los s of rotary vane feeder, RVF, signal for this emission control system 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 or remote monitoring station for more than six (6) hours in any twenty

- four (24) hour period or loss of a measurement device component that results in a RVF

- hours per day parametric that is b elow the established limit of 1.8 tons per hour.

1

. The operator or technician is to confirm the system status, noting which PLC is off line or which compartments have suffered signal loss. The operator is to log the time that the condition was first noti ced 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 and Environmental personnel and/or initiate a maintenance work order, or restart the PLC.

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.

Note: All revisions to this plan are to be retained for five (5) years from their date of issue.Green Mill Startup, Shutdown and Malfunction Plan Page 8 of 9 Alcoa

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### Condition: Catastrophic Failure of Fume Control Equipment In the event of catastrophic failure of emission control equipment or components in this emission control system 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 unit or duct, a direct lightnin g strike, 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 or proxy is to confirm the system status, noting w hich components 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 re sponse, the operator or proxy is to notify appropriate Maintenance, Engineering, Environmental 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 p ersonnel 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 ent ered 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.Green Mill Startup, Shutdown and Malfunction Plan Page 9 of 9 Alcoa

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### Condition: Visible Emissions

- Dusting Stack(s) In the event that emi ssions outside the normal operating range are visibly being emitted from the exhaust(s) of this emission control system the following malfunction and corrective action plan must be initiated within one hour of first becoming aware of a malfunction.

Exampl es of visible emissions or dusting stack(s) include, but are not limited to; continuous visible emissions noted by the Operator from the stack of the emission control device.

1

. The operator is to report the dusting stack from any source including, but not l imited to the daily visual checks made by the Emission Control Shift Technician. The operator is to log the time that the condition was first noticed or reported and also log the time at which he/she reported emissions or initiated this plan.

2

. Following t his initial response, the operator or proxy is to make arrangements to have the baghouse 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 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 in the visible emission log. Maintenance or Environmental perso nnel 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 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.