Facility DEC ID: 6405800003
PERMIT Under the Environmental Conservation Law (ECL) IDENTIFICATION INFORMATION Permit Type: Air Title V Facility Permit ID: 6-4058-00003/00365 Effective Date: 09/01/2002 Expiration Date: 09/01/2007 Permit Issued To: ALCOA INC 201 ISABELLA ST PITTSBURGH, PA 15212-5858 Contact: JAMES M SHAW ALCOA INC PO BOX 150 MASSENA, NY 13662-0150 (315) 764-4126 Facility: ALCOA MASSENA OPERATIONS (WEST PLANT) PARK AVENUE EAST MASSENA, NY 13662 Contact: JAMES M SHAW ALCOA INC PO BOX 150 MASSENA, NY 13662-0150 (315) 764-4126 Description:
By acceptance of this permit, the permittee agrees that the permit is contingent upon strict compliance with the ECL, all applicable regulations, the General Conditions specified and any Special Conditions included as part of this permit. Permit Administrator: BRIAN D FENLON STATE OFFICE BLDG 317 WASHINGTON ST WATERTOWN, NY 13601- 3787 Authorized Signature: _________________________________ D ate: ___ / ___ /

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FINALFacility DEC ID: 6405800003 Notification of Other State Permittee Obligations
Item A: Permittee Accepts Legal Responsibility and Agrees to Indemnification The permittee expressly agrees to indemnify and hold harmless the Department of Environmental Conservation of the State of New York, its representatives, employees, and agents ("DEC") for all claims, suits, actions, and damages, to the extent attributable to the permittee's acts or omi ssions in connection with the permittee's undertak ing of activities in connection with, or operation and maintenance of, the facility or facilities authorized by the permit whether in compliance or not in compliance with the terms and conditions of the permit. This indemnification does not extend to any claims, suits, actions, or damages to the extent attributable to DEC's own negligent or intentional acts or omissions, or to any claims, suits, or actions naming the DEC and arising under article 78 of the New York Civil Practice Laws and Rules or any citizen suit or civil rights provision under federal or state laws.

Item B: Permittee's Contractors to Comply with Permit The permittee is responsible for informing its independent contractors, employees, agents and assigns of their responsibility to comply with this permit, including all s pecial conditions while acting as the permittee's agent with respect to the permitted activities, and such persons shall be subject to the same sanctions for violations of the Environmental Conservation Law as those prescribed for the permittee.

Item C: Permittee Responsible for Obtaining Other Required Permits The permittee is responsible for obtaining any other permits, approvals, lands, easements and rights-of-way that may be required to carry out the activities that are authorized by this permit.

Item D: No Right to Trespass or Interfere with Riparian Rights This permit does not convey to the permittee any right to t respass upon the la nds or interfere with the riparian rights of others in order to perform the permitted work nor does it authorize the impairment of any rights, title, or interest in real or personal property held or vested in a person not a party to the permit.

FINALFacility DEC ID: 6405800003 LIST OF CONDITIONS

DEC GENERAL CONDITIONS General Provisions Facility Inspection by the Department Relationship of this Permit to Other Department Orders and Determinations Applications for Permit Renewals and Modifications Permit Modifications, Suspensions and Revocations by the Department Facility Level Submission of Applications for Permit Modification or Renewal -REGION 6 HEADQUARTERS

DEC Permit Conditions Page 1 of 3 FINALFacility DEC ID: 6405800003 DEC GENERAL CONDITIONS **** General Prov isions   n0 For the purpose of your Title V permit, the following section contains state-only enforcable terms and conditions GENERAL CONDITIONS - Apply to ALL Authorized Permits.

Condition 1: Facility Inspection by the Department Applicable State Requirement: ECL 19-0305. Item 1.1: The permitted site or facility, including relevant records, is subject to inspection at reasonable hours and intervals by an authorized representative of the Department of Environmental Conservation (the Department) to determine whether the permittee is complying with this permit and the ECL. Such representative may order the work susp ended pursuant to ECL 71-0301 and SAPA 401(3). Item 1.2: The permittee shall provide a person to accompany the Department's representative during an inspection to the permit area when requested by the Department. Item 1.3: A copy of this permit, including all referenced ma ps, drawings and special conditions, must be available for inspection by the Department at all times at the project site or f acility. Failure to produce a copy of the permit upon request by a Department re presentative is a violation of this permit. Condition 2: Relationship of this Permit to Other Department Orders and Determinations Applicable State Requirement: ECL 3-0301.2(m) Item 2.1: Unless expressly provided for by the Department, issuance of this permit does not modify, supersede or rescind any order or determination previously issued by the Department or any of the terms, conditions or requirements contained in such order or determination. Condition 3: Applications for Permit Renewals and Modifications Applicable State Requirement: 6NYCRR 621.13 Item 3.1: The permittee must submit a separate written appli cation to the Department for renewal, modification or transfer of this permit. Such application must include any forms or supplemental information the Department requires. Any renewal, modification or transfer granted by the Department must be in writing. Item 3.2: The permittee must submit a renewal application at least 180 days before expiration of permits for T itle V Facility Permits, or at least 30 days before expiration of permits for State Facility Permits. Item 3.3: Permits are transferrable with the approval of the department unless specifically prohibited by the statute, DEC Permit Conditions Page 2 of 3 FINALFacility DEC ID: 6405800003 regulation or another permit condition. Applications for permit transfer should be submitted prior to actual transfer of ownership. Condition 4: Permit Modifications, Suspensions and Revocations by the Department Applicable State Requirement: 6NYCRR 621.14 Item 4.1: The Department reserves the right to modify, suspend, or revoke this permit in accordance with 6NYCRR Part 621. The gr ounds for modification, suspension or revocation include: a) materially false or inaccurate statements in the permit application or supporting papers; b) failure by the permittee to comply w ith any terms or conditions of the permit; c) exceeding the scope of the project as described in the permit application; d) newly discovered material information or a material change inenvironmental cond itions, relevant technology or a pplicable law or regul ations since the issuance of the existing p ermit; e) noncompliance with previously issued permit conditions, orders of the commissioner, any provisions of the Environmental Conservation Law or regulations of the Department related to the permitted activity.

** ** Fac ility Level   Condition 5: Submission of Applications for Permit Modification or Renewal -REGION 6 HEADQUARTERS Applicable State Requirement: 6NYCRR 621.5(a) Item 5.1: Submission of applications for pe rmit m odification or renewal are to be submitted to: NYSDEC Regional Permit Administrator Region 6 Headquarters Division of Environmental Permits State Office Building, 317 Washington Street Watertown, NY 13601-3787 (315) 785-2245

DEC Permit Conditions Page 3 of 3 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Permit Under the Environmental Conservation Law (ECL) ARTICLE 19: AIR POLLUTION CO NTROL - TI TLE V PERMIT IDENTIFICATION INFORMATION Permit Issued To: ALCOA INC 201 ISABELLA ST PITTSBURGH, PA 15212-5858 Contact: JAMES M SHAW ALCOA INC PO BOX 150 MASSENA, NY 13662-0150 (315) 764-4126 Facility: ALCOA MASSENA OPERATIONS (WEST PLANT) PARK AVENUE EAST MASSENA, NY 13662 Contact: JAMES M SHAW ALCOA INC PO BOX 150 MASSENA, NY 13662-0150 (315) 764-4126 Authorized Activity By Standard Industrial Classification Code: 3334 - PRIMARY ALUMINUM 3354 - ALUMINUM EXTRUDED PRODUCTS

Air Po llution Control Permit Conditions Page 1 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 LIST OF CONDITIONS

FEDERALLY ENFORCEABLE CONDITIONS Facility Level 1 Surface Coating Exemption 2 Emission Unit Definition 3 Recordkeeping and reporting of compliance monitoring 4 Monitoring, Related Recordkeeping, and Reporting Requirements. 5 Compliance Certification 6 Compliance Certification 7 Non Applicable requirements 8 Required Emissions T ests - Fac ility Level 9 Compliance Certification 10 Recordkeeping requirements 11 Compliance Certification 12 Compliance Certification 13 Compliance Certification 14 Compliance Certification 15 Compliance Certification 16 Equipment Specifications for Cold Cleaning Batch Degreasing 17 Compliance Certification 18 Compliance Certification 19 Compliance Certification 20 Incorporation by Reference 21 Compliance Provisions - Test Plan 22 Compliance Certification 23 Reference test methods for TF and POM emissions 24 Alternative test methods for TF or POM emissions 25 Accidental release provisions. 26 Recycling and Emissi ons Reduction Emission Unit Level 27 Emission Point Definition By Emission Unit 28 Process Definition By Emission Unit 29 Compliance Certification (EU=A- 00001,EP=F078A,Proc=HT2,ES=AF78A) 30 Compliance Certification (EU=A- 00001,EP=F078B,Proc=HT2,ES=AF78B) 31 Compliance Certification (EU=A -00002,Proc=FAB) 32 Compliance Certification (EU=A -00002,Proc=MRS) 33 Compliance Certification (EU=A -00002,Proc=MRS) 34 Corrective Action 35 Corrective Action 36 Corrective Action 37 Corrective Action 38 General Provisions 39 Compliance Certificati on (EU=B-00001) 40 Compliance Certification (EU=B -00001,Proc=OIL) 41 Compliance Certification (EU=B -00001,Proc=OIL) Air Po llution Control Permit Conditions Page 2 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 42 Records retention 43 Sulfur in fuel exception reporting 44 Compliance Certification (EU=B -00001,Proc=OIL) 45 Sampling, compositing, and analysis of fuel samples 46 Compliance Certification (EU=B -00001,Proc=OIL) 47 Compliance Certification (EU=B -00001,Proc=O IL,ES=B0001) 48 Compliance Certification (EU=B -00001,Proc=O IL,ES=B0002) 49 Compliance Certification (EU=B -00001,Proc=O IL,ES=B0003) 50 Compliance Certification (EU=B -00001,Proc=O IL,ES=B0004) 51 Compliance Certification (EU=B- 00001,EP=00001, Proc=GAS) 52 Compliance Certification (EU=B- 00001,EP=00001,Proc=OIL) 53 Compliance Certification (EU=B- 00001,EP=00002, Proc=GAS) 54 Compliance Certification (EU=B- 00001,EP=00002,Proc=OIL) 55 Compliance Certificati on (EU=C-00001) 56 Compliance Certificati on (EU=C-00001) 57 Compliance Certificati on (EU=C-00001) 58 Compliance Certification (EU=C -00001,Proc=CD1 ,ES=C029B) 59 Compliance Certification (EU=C -00001,Proc=CD1 ,ES=C029B) 60 Compliance Certification (EU=C- 00001,EP=I0029,Proc=CD1) 61 Compliance Certification (EU=C- 00001,EP=I0029,Proc=CD1) 62 Compliance Certification (EU=C- 00001,EP=I0030,Proc =CM1,ES=C0030) 63 Compliance Certificati on (EU=C-00002) 64 Compliance Certificati on (EU=C-00002) 65 Compliance Certificati on (EU=C-00002) 66 Compliance Certificati on (EU=C-00002) 67 Compliance Certification (EU=C -00002,Proc=CD2) 68 Compliance Certification (EU=C -00002,Proc=CD2) 69 Compliance Certification (EU=C -00002,Proc=CD2 ,ES=C044B) 70 Compliance Certification (EU=C -00002,Proc=CD2 ,ES=C044B) 71 Compliance Certification (EU=D -00001,Proc=PRT) 72 Compliance Certification (EU=D -00001,Proc=PRT) 73 method 24 40 CFR 60 74 samples 75 Compliance Certification (EU=D -00001,Proc=PRT) 76 Compliance Certification (EU=D -00001,Proc=PRT) 77 Compliance Certification (EU=D -00001,Proc=PRT ,ES=DF073) 78 Compliance Certificati on (EU=M-00001) 79 Compliance Certificati on (EU=M-00001) 80 Compliance Certificati on (EU=M-00001) 81 Compliance Certificati on (EU=M-00001) 82 Calculation of Sec ondary A luminum Processing Unit PM emi ssions 83 Compliance Certificati on (EU=M-00001) 84 Compliance Certificati on (EU=M-00001) 85 Compliance Certificati on (EU=M-00001) 86 Compliance Certificati on (EU=M-00001) 87 Testing of Representative Emission Units 88 Compliance Certificati on (EU=M-00001) 89 Compliance Certificati on (EU=M-00001) Air Po llution Control Permit Conditions Page 3 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 90 Performance Test/Compliance Demonstration Requirements and Procedures - Feed/Charge Weight Measurement. 91 Compliance Certificati on (EU=M-00001) 92 Equations for Determining Compliance - Secondary Alumi num Processing Unit 93 Compliance Certificati on (EU=M-00001) 94 Compliance Certificati on (EU=M-00001) 95 Compliance Certification (EU=M- 00001,EP=I003C,Proc=MHS,ES=M003C) 96 Compliance Certification (EU=M- 00001,EP=I024F,Proc=MHA,ES=M024F) 97 Compliance Certificati on (EU=M-00002) 98 Compliance Certificati on (EU=M-00002) 99 Compliance Certificati on (EU=M-00002) 100 Comp liance Certificati on (EU=M-00002) 101 Calculation of Sec ondary A luminum Processing Unit PM emi ssions 102 Comp liance Certificati on (EU=M-00002) 103 Comp liance Certificati on (EU=M-00002) 104 Comp liance Certificati on (EU=M-00002) 105 Comp liance Certificati on (EU=M-00002) 106 Testing of Represent ative Emission Units 107 Comp liance Certificati on (EU=M-00002) 108 Comp liance Certificati on (EU=M-00002) 109 Perfor mance Test/Compliance Demonstration Requirements and Procedures - Feed/Charge Weight Measurement. 110 Comp liance Certificati on (EU=M-00002) 111 Equations for Determining Comp liance - Secondary Alumi num Processing Unit 112 Comp liance Certificati on (EU=M-00002) 113 Comp liance Certificati on (EU=M-00002) 114 General requirements 115 Comp liance Certification (EU= P-00001,Proc=PWS) 116 Comp liance Certification (EU= S-00001,Proc=POT) 117 Comp liance Certification (EU= S-00001,Proc=POT) 118 Comp liance Certification (EU= S-00001,Proc=POT) 119 Perfor mance Test Requirements - Pr evious Control Device T ests 120 Potline TF emissi on rate calculation 121 P rocedure to determine weights 122 Calculation of aluminum production rate 123 S election of monitoring parameters - potlines and anode bake furn aces 124 S election of monitoring parameters - redetermining operating limits 125 Comp liance Certification (EU= S-00001,Proc=POT) 126 R educed sampling frequency - contents of request letter 127 R educed sampling frequency requ est - contents of the approved alternative requirement 128 Comp liance Certification (EU= S-00001,Proc=POT) 129 Comp liance Certification (EU= S-00001,Proc=POT) 130 Comp liance Certification (EU= S-00001,Proc=POT) 131 Corrective action pro cedures 132 E xceedances Air Po llution Control Permit Conditions Page 4 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 133 Comp liance Certification (EU= S-00001,Proc=POT) 134 Accu racy and calibration requirements 135 Alternative operati ng parameters 136 Def inition of potline in Met hod 14 137 In stallation of manifolds for po tlines subject to Method 14 138 Perfor mance test reports 139 Startup, shutdown, and malfunction plan and reports 140 Startup, shutdown, and malfunction plan and reports 141 Comp liance Certification (EU= S-00001,Proc=POT) 142 Comp liance Certification (EU= S-00001,Proc=POT) 143 Comp liance Certification (EU= S-00001,Proc=POT) 144 Comp liance Certification (EU= S-00001,Proc=POT) 145 Comp liance Certification (EU= S-00001,Proc=POT) 146 Comp liance Certification (EU= S-00002,Proc=BAK) 147 Comp liance Certification (EU= S-00002,Proc=BAK) 148 Perfor mance Test Requirements - Pr evious Control Device T ests 149 Comp liance Certification (EU= S-00002,Proc=BAK) 150 Comp liance Certification (EU= S-00002,Proc=BAK) 151 Calculation of anode bake furn ace TF emission rate 152 Calculation of anode bake furnace POM emission rate 153 P rocedure to determine weights 154 Determination of rate of green anode introduction into furnace 155 S election of monitoring parameters - potlines and anode bake furn aces 156 S election of monitoring parameters - redetermining operating limits 157 Comp liance Certification (EU= S-00002,Proc=BAK) 158 Comp liance Certification (EU= S-00002,Proc=BAK) 159 Comp liance Certification (EU= S-00002,Proc=BAK) 160 Comp liance Certification (EU= S-00002,Proc=BAK) 161 Comp liance Certification (EU= S-00002,Proc=BAK) 162 Corrective action pro cedures 163 E xceedances 164 Comp liance Certification (EU= S-00002,Proc=BAK) 165 Accu racy and calibration requirements 166 Alternative operati ng parameters 167 Perfor mance test reports 168 Startup, shutdown, and malfunction plan and reports 169 Startup, shutdown, and malfunction plan and reports 170 Comp liance Certification (EU= S-00002,Proc=BAK) 171 Comp liance Certification (EU= S-00002,Proc=BAK) 172 Comp liance Certification (EU= S-00002,Proc=BAK) 173 Comp liance Certification (EU= S-00002,Proc=BAK) 174 Comp liance Certification (EU= S-00002,Proc=BAK) 175 Comp liance Certification (EU=S- 00002,EP=S0078,Proc =BAK,ES=SS078) 176 Comp liance Certification (EU=S- 00002,EP=S0078,Proc =BAK,ES=SS078) 177 Emission Limits for Existing Sources - Paste Production Plants 178 In itial compliance provisions for paste production plants 179 S election of monitoring parameters - paste production plants 180 S election of monitoring parameters - redetermining operating limits Air Po llution Control Permit Conditions Page 5 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 181 Comp liance Certificati on (EU=S-00003) 182 Comp liance Certificati on (EU=S-00003) 183 Comp liance Certificati on (EU=S-00003) 184 Corrective action pro cedures 185 E xceedances 186 Accu racy and calibration requirements 187 Alternative operati ng parameters 188 Startup, shutdown, and malfunction plan and reports 189 Startup, shutdown, and malfunction plan and reports 190 Comp liance Certificati on (EU=S-00003) 191 Comp liance Certificati on (EU=S-00003) 192 Comp liance Certificati on (EU=S-00003) 193 Comp liance Certificati on (EU=S-00003) 194 Comp liance Certificati on (EU=S-00003) 195 Comp liance Certification (EU=S- 00003,EP=S0100) 196 Comp liance Certification (EU= S-00004,Proc=M 01,ES=SS017) 197 Comp liance Certification (EU= S-00004,Proc =M16) 198 Comp liance Certification (EU= S-00005,Proc =PST) 199 Comp liance Certification (EU=W -00001,Proc =WWT) 200 Comp liance Certification (EU=W -00001,Proc =WWT) STATE ONLY ENFORCEABLE CONDITIONS Facility Level 201 Contaminant List 202 Unavoidable noncompliance and viola tions 203 Comp liance Demonstration 204 Emissions other than total fluorides 205 Air pollution prohibited 206 Comp liance Demonstration 207 Comp liance Demonstration 208 Comp liance Demonstration Emission Unit Level 209 Comp liance Demonstration 210 Comp liance Demonstration 211 Comp liance Demonstration 212 Comp liance Demonstration 213 Comp liance Demonstration 3355 - ALUMINUM ROLLING & DRAWING NEC Permit Effective Date: 09/01/2002 Permit Expiration Date: 09/01/2007

Air Po llution Control Permit Conditions Page 6 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 FEDERALLY ENFORCEABLE CONDITIONS ** ** Fac ility Level  

NOTIFICATION OF GENERAL PERMITTEE OBLIGATIONS The items listed below are not subject to the a nnual com pliance certification requirements under Title V. Permittees may also have other obligations under regulations of general applicability. Item A: Sealing - 6NYCRR Part 200.5 The Commissioner may seal an air contamination source to prevent its operation if compliance with 6 NYCRR Chapter III is not met within the time provided by an order of the Commissioner issued in the case of the violation. Sealing means labeling or tagging a source to notify any person that operation of the source is prohibited, and also includes physical means of preventing the operation of an air contamination source without resulting in destruction of any equipm ent associated with such source, and includes, but is not lim ited to, bolting, chaining or wiring shut control panels, apertures or conduits associated with such source. No person shall operate any air contamination source sealed by the Commissioner inaccordance with this section unless a modification has been made which enables such source to comply with all requ irements applicable to such modification. Unless authorized by the Commissioner, no person shall remove or alter any seal affixed to any contamination source in accordance with this section.
Item B: Acceptable Ambient Air Quality - 6 NYCRR Part 200.6 Notwithstanding the provisions of 6 NYCRR Chapter III, Subchapter A, no person shall allow or permit any air contamination source to emit air contaminants in quantities which alone or in combination with emissions from other air contamination sources would contravene any applicable ambient air quality s tandard and/or cause air pollution. In such cases where contravention o ccurs or may occur, the Commissioner shall specify the degree and/or method of emission control required. Item C: Maintenance of Equipment - 6NYCRR Part 200.7 Any person who owns or o perates an air c ontamination Air Po llution Control Permit Conditions Page 7 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 source which is equipped with an emission control device shall operate such device and keep it in a satisfactory state of maintenance and repair in accordance with ordinary and necessary practices, standards and procedures, inclusive of manufacturer's specifications, required to operate such device effectively.
Item D: Unpermitted Emission Sources - 6NYCRR Part 201-1.2 If an existing emission source was subject to the permitting requirements of 6NYCRR Part 201 at the time of construction or modification, and the owner and/or operator failed to apply for a permit for such emission source then the following provisions apply: (a) The owner and/or operator must apply for a permit for such emission source or register the facility in accordance with the provisions of Part 201. (b) The emission source or facility is subject to all regulations that were app licable to it at the time of construction or modification and any subsequent requirements applicable to existing sources or facilities.
Item E: Emergency Defense - 6NYCRR Part 201-1.5 An emergency constitutes an affirmative defense to an action brought for noncompliance with emissions limitations or permit conditions for all facilities in New York State. (a) The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous operating logs, or ot her relevant evidence that: (1) An emergency occurred and that the facility owner and/or operator can identify the cause(s) of the emergency; (2) The equipment at the permitted facility causing the emergency was at the time being properly operated; (3) During the period of the emergency the facility owner and/or operator took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in the permit; and (4) The facility owner and/or operator notified the Department within two work ing days after the event occurred. This notice must contain a description of the Air Po llution Control Permit Conditions Page 8 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 emergency, any steps taken to mitigate emissions, and corrective actions taken. (b) In any enforcement pro ceeding, the facility owner and/or operator seeking to establish the occurrence of an emergency has the burden of proof. (c) This provision is in addition to any emergency or upset provision contained in any applicable requirement.
Item F: Recycling and Salvage - 6NYCRR Part 201-1.7 Where practical, any pe rson who owns or operates an air contamination source shall recycle or salvage air contaminants collected in an air cleaning device according to the requirements of 6 NYCRR. Item G: Prohibition of Reintroduction of Collected Contaminants to the Air - 6NYCRR Part 201-1.8 No person shall unnecessarily remove, handle, or cause to be handled, collected air contaminants from an air cleaning device for recycling, salvage or disposal in a manner that would reintroduce them to the outdoor atmosphere.
Item H: Public Access to Recordkeeping for Title V Facilities - 6NYCRR Part 201-1.10(b) The Department will makeavailable to the public any permit application, comp liance plan, permit, and monitoring and compliance certification report pursuant to Section 503(e) of the Act, except for information en titled to confidential treatment pursuant to 6NYCRR Part 616 - Public Access to records and Section 114(c) of the Act.
Item I: Proof of Eligibility for Sources Defined as Exempt Activities - 6 NYCRR Part 201-3.2(a) The owner and/or operator of an emission source or unit that is eligible to be exempt, m ay be required to certify that it operates w ithin the specifi c criteria described in 6 NYCRR Subpart 201-3. The owner or operator of any such emission source must maintain all required records on-site for a period of five y ears and make them available to representatives of the Department upon request. Department representatives must be granted access to any facility which contains emission sources or units subject to 6 NYCRR Subpart 201-3, during normal o perating hours, for the purpose of determini ng compliance with this and any other state and federal ai r pollution control Air Po llution Control Permit Conditions Page 9 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 requirements, regulations, or law.
Item J: Proof of Eligibility for Sources Defined as Trivial Activities - 6 NYCRR Part 201-3.3(a) The owner and/or operator of an emission source or unit that is listed as being trivial in 6 NYCRR Part 201 may be required to certify that it operates w ithin the specific criteria described in 6 NYCRR Subpart 201-3. The owner or operator of any such emission source must maintain all required records on-site for a period of five years and make them available to representatives of the Department upon request. Department representatives must be granted access to any facility which contains emission sources or units subject to 6 NYCRR Subpart 201-3, during normal operating hours, for the purpose of determining compliance with this and any othe r state and federal ai r pollution control requirements, regulations, or law.
Item K: Timely Application for the Renewal of Title V Permits - 6 NYCRR Part 201-6.3(a)(4) Owners and/or operators of facilities having an issued Title V permit shall submit a complete application at least 180 days, but not more than eighteen months, prior to the date of permit expiration for permit renewal purposes. Item L: Certification by a Responsible Official - 6 NYCRR Part 201-6.3(d)(12) Any application, form, report or compliance certification required to be subm itted pursuant to the federally enforceable portions of this permit shall contain a certification of truth, accuracy and completeness by a responsible official. This certification shall state that based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.
Item M: Requirement to Comply With All Co nditions - 6 NYCRR Part 201-6.5(a)(2) The permittee must comply w ith all conditions of the Title V facility permit. Any permit non-compliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application.
Item N: Permit Revocation, Modification, Reopening, Reissuance or Termination, and Associated Information Submission Air Po llution Control Permit Conditions Page 10 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Requirements - 6 NYCRR Part 201-6.5(a)(3) This permit may be modified, revoked, reopened and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or antic ipated noncomp liance does not stay any permit condition. Item O: Providing Information Upon Request - 6 NYCRR Part 201-6.5(a)(4) The permittee shall furnish to the Department, within a 

### ard reasonable time, any information that the Department may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating the permit or to determine compliance with the permit. The permittee shall also, on request, furnish the Department with copies of records required to be kept by the permit. Where information is claimed to be confidential, the permittee may furnish such records directly to the Administrator along with a claim of confidentiality.
Item P: Cessation or Reduction of Permitted Activity Not a Defense - 6NYCRR Part 201-6.5(a)(5) It shall not be a defense for a permittee in an enforcement action to claim that a cessation or reduction in the permitted activity would have been necessary in order to maintain compliance with the conditions of this permit. Item Q: Property Rights - 6 NYCRR Part 201-6.5(a)(6) This permit does not convey any property rights of any sort or any exclusive privilege.
Item R: Fees - 6 NYCRR Part 201-6.5(a)(7) The owner and/or operator of a stationary source shall pay fees to the department consistent with the fee schedule authorized by 6 NYCRR Subpart 482-2. Item S: Right to Inspect - 6 NYCRR Part 201-6.5(a)(8) Upon presentation of cr edentials and other documents, as may be required by law, the permittee shall allow the Department or an authorized representative to perform the following:

Air Po llution Control Permit Conditions Page 11 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 i. Enter upon the permittee's premises where the permitted facility is located or emissi ons-related activity is conducted, or where records must be kept under the conditions of the permit; ii. Have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit; iii. Inspect, at reasonable times, any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the permit; and iv. As authorized by the Act, sample or monitor, at reasonable times, substances or parameters for the purpose of assuring compliance with the permit or applicable requirements.
Item T: Severability - 6 NYCRR Part 201-6.5(a)(9) If any provisions, parts or conditions of this permit are found to be invalid or are the subject of a challenge, the remainder of this permit sh all continue to be valid.
Item U: Progress Reports and Compliance Schedules - 6 NYCRR Part 201-6.5(d)(5) Progress reports consistent with an applicable schedule of compliance must be submitted at l east semiannually on a calendar year basis, or at a more frequent period if specified in the applicable requirement or by the Department elsewhere in this permit. These reports shall be submitted to the Department within 30 days after the end of a reporting period. Such progress reports shall contain the following: i. Dates for achieving the activities, milestones, or compliance required in the schedule of compliance, and dates when such activities, milestones or compliance were achieved; and ii. An explanation of why any dates in the schedule of compliance were not or will not be met, and any preventive or corrective measures adopted.
Item V: Off Permit Changes - 6 NYCRR Part 201-6.5(f)(6) No permit revision will be required for operating changes Air Po llution Control Permit Conditions Page 12 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 that contravene an express permit term, provided that such changes would not violate applicable requirements as defined under this Part or contravene federa lly enforceable monitoring (including test methods), recordkeeping, reporting, or compliance certification permit terms and conditions. Such changes may be made without requiring a perm it revision, if the changes are not modifications under any provisions of Title I of the Act and the changes do not exceed the emissions allowable under the permit (whether expressed therein as a rate of emissions or in terms of total emissions) provided that the facility provides the Administrator and the Department with written notification in advance of the proposed changes within a minimum of 7 days as required by 6 NYCRR §201-6.5(f)(6).
Item W: Permit Shield - 6 NYCRR Part 201-6.5(g) All permittees granted a Title V facility permit shall be covered under the protection of a permit shield, except as provided under 6 NYCRR Subpart 201-6. Comp liance with the conditions of the permit shall be deemed compliance with any applicable requirements as of the date of permit issuance, provided that such applicable requirements are included and are specifically identified in the permit, or the Department, in acting on the permit application or revision, determines in writing that other requirements specifically identified are not applicable to the major stationary source, and the permit includes the determination or a concise summary thereof. Nothing herein shall preclude the Department from revising or revoking the permit pursuant to 6 NYCRR Part 621 or from exercising its summary abatementauthority. Nothing in this permit shall alter or affect the following: i. The ability of the Department to seek to bring suit on behalf of the State of New York, or the Administrator to seek to bring suit on behalf of the United States, to immediately restrain any person causing or contributing to pollution presenting an i mminent and substantial endangerment to public health , welfare or the environment to stop the emission of air pollutants causing or contributing to such pollution; ii. The liability of a permittee of the Title V facility for any violation of applicable requirements prior to or at the time of permit issuance;

Air Po llution Control Permit Conditions Page 13 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 iii. The applicable requirements of Title IV of the Act; iv. The ability of the Department or the Administrator to obtain information from the permittee concerning the ability to enter, inspect and monitor the facility.
Item X: Reopening for Cause - 6 NYCRR Part 201-6.5(i) This Title V permit shall be reopened and revised under any of the following circumstances: i. If additional applicable requirements under the Act become applicable where this permit's remaining term is three or more years, a reopening shall be completed not later than 18 months after promulgation of the applicable requirement. No such reopening is required if the effective date of the re quirement is later than the date on which this permit is due to expire, unless the original permit or any of its terms and conditions has been extended by the Department pursuant to the provisions of Part 201-6.7 and Part 621. ii. The Department or the Administrator determines that the permit contains a materi al mistake orthat inaccurate statements were made in establishing the emissi ons standards or other terms or conditions of the permit. iii. The Department or the Administrator determines that the Title V permit must be revised or reopened to assure compliance with applicable requirements. iv. If the permitted facility is an "affected source" subject to the requirements of Title IV of the Act, and additional requirements (including excess emissions requirements) become applicable. Upon approval by the Administrator, excess emissions offset plans shall be deemed to be incorporated into the permit. Proceedings to reopen and issue Title V facility permits shall follow the same procedures as apply to initial permit issuance but shall aff ect only those parts of the permit for which cause to reopen exists. Reopenings shall not be initiated before a notice of such intent is provided to the fac ility by the Department at least thirty days in advance of the date that the permit Air Po llution Control Permit Conditions Page 14 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 is to be reopened, except that the Department may provide a shorter time period in the case of an emergency.
Item Y: Required Emission Tests - 6 NYCRR Part 202-1.1 An acceptable report of measured emissions shall be submitted, as may be required by the Commissioner, to ascertain compliance or noncompliance with any air pollution code, rule, or regulation. Failure to submit a report acceptable to the Commissioner within the time stated shall be sufficient reason for the Commissioner to suspend or deny an operating permit. Notification and acceptable procedures are specified in 6NYCRR Part 202-1.
Item Z: Visible Emissions Limited - 6 NYCRR Part 211.3 Except as permitted by a specific part of this Subchapter and for open fires for which a restricted burning permit has been issued, no person shall cause or allow any air contamination source to emit any material having an opacity equal to or greater than 20 percent (six minute average) except for one conti nuous six-minute period per hour of not more than 57 percent opacity. Item AA: Open Fires - 6 NYCRR Part 215 No person shall burn, cause, suffer, allow or permit the burning in an open fire of garbage, rubbish for salvage, or rubbish generated by industrial or commercial activities.
Item BB: Permit Exclusion - ECL 19-0305 The issuance of this permit by the Department and the receipt thereof by the Applicant does not and shall not be construed as barring, diminishing, adjudicating or in any way affecting any legal, administrative or equitable rights or claims, actions, suits, causes of action or demands whatsoever that the Department may have against the Applicant for violations based on facts and circumstances alleged to have occurred or existed prior to the effective date of thi s permit, including, but not limited to, any enforcement action authorized pursuant to the provisions of applicable federal law, the Environmental Conservation Law of the State of New York (ECL) and Chapter III of the Official Compilation of the Codes, Rules and Regulations of the State of New York (NYCRR). The issuance of this permit also shall not in any way affect pending or future enforcement actions under the Clean Air Act brought by the United States or any person.

Air Po llution Control Permit Conditions Page 15 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Item CC: Federally Enforceable Requirements - 40 CFR 70.6(b) All terms and conditions in this permit required by the Act or any applicable requirement, including any provisions designed to limit a facility's potential to emit, are enfor ceable by the Administrator and citizens under the Act. The Department has, in this permit, specifically designated any terms and conditions that are not required under the Act or under any of its applicable requirements as being enforceable under only state regulations.

FEDERAL APPLICABLE REQUIREMENTS The following conditions are subject to annual compliance certification requirements for Title V permits only.

Condition 1: Surface Coating Exemption Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 201-3.2(c)(17) Item 1.1: The following activity is exempt from permitting requir ements, but must be incl uded in the Title V permit application: Surface coating and related operations which uses less than 25 gallons per month of coating materials (paints) and cleaning solvents, combined, subject to the following: (i) the facility is located out side of any severe ozone non attainment area; and (ii) all abrasive cleaning and surface coating operations are performed in an enclosed building w here such operations are exhausted into appropriate emiss ion control devices. Condition 2: Emission Unit Definition Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 201-6. Item 2.1: The facility is authorized to perform regulated processes under this permit for: Emission Unit: A-00001 Emission Unit Description: PROCESS HEATERS TREAT SOLID ALUMINUM AND EMIT SMALL QUANTITIES OF PROCESS EMISSIONS DUE TO RESIDUALS ON THE ALUMINUM. EMISSIONS CO-MINGLE WITH PRODUCTS-OF-COMBUSTION (POC) FROM NATURAL GAS BURNERS. Building(s): 131 Air Po llution Control Permit Conditions Page 16 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 140 222 234 Item 2.2: The facility is authorized to perform regulated processes under this permit for: Emission Unit: A-00002 Emission Unit Description: INSIGNIFICANT SHOP SOURCES. Building(s): 131 140 Item 2.3: The facility is authorized to perform regulated processes under this permit for: Emission Unit: B-00001 Emission Unit Description: FOUR VIRTUALLY IDENTICAL PACKAGE BOILERS FIRING EITHER NATURAL GAS OR #6 FUEL OIL. Building(s): 216A Item 2.4: The facility is authorized to perform regulated processes under this permit for: Emission Unit: C-00001 Emission Unit Description: CHIP DRYER #1 WITH ASSOCIATED CONTROL EQUIPMENT (CYCLONE AND AFTERBURNER) AND CHIP MELTER #1. Building(s): 221 Item 2.5: The facility is authorized to perform regulated processes under this permit for: Emission Unit: C-00002 Emission Unit Description: CHIP DRYER #2 WITH ASSOCIATED CONTROL EQUIPMENT (CYCLONE AND THERMAL OXIDIZER) AND CHIP MELTER #2. Building(s): 221 Item 2.6: The facility is authorized to perform regulated processes under this permit for: Emission Unit: D-00001 Emission Unit Description: MISCELLANEOUS POINT SOURCES.

Air Po llution Control Permit Conditions Page 17 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Building(s): 140 220 222 Item 2.7: The facility is authorized to perform regulated processes under this permit for: Emission Unit: F-00001 Emission Unit Description: ALCOA ENGINEERED PRODUCTS (AEP) FUGITIVES. Building(s): 131 140 220 222 Item 2.8: The facility is authorized to perform regulated processes under this permit for: Emission Unit: M-00001 Emission Unit Description: ALUMINUM MELTING AND HOLDING FURNACES. ALL FURNACES ARE REVERBERATORY, CENTER CHARGED. FURNACE CHARGE MOLTEN ALUMINUM, CLEAN SCRAP, ALLOYING INGREDIENTS AND SALT. NO GAS FLUXING IS DONE IN ANY FURNACE. Building(s): 221 Item 2.9: The facility is authorized to perform regulated processes under this permit for: Emission Unit: M-00002 Emission Unit Description: IN-LINE FILTERB BOX FLUXING UNITS USE A MIXTURE OF ARGON AND CHLORINE GAS TO PURIFY MOLTEN ALUMINUM AS IT IS BEING CAST INTO INGOTS OR ROD. TYPICALLY THERE IS ONE FILTERBOX PER FURNACE, AND MULITPLE FURNACES/FILTERBOXES SERVE A SINGLE CASTING COMPLEX. WI THIN A CASTING COMPLEX, THESE FILTERBOXES CAN BE EXHAUSTED TO GETHER OR INDIVIDUALLY, HOWEVER, ONLY ONE FILTER BOX IS FLUXING AT ANY TIME SINCE THERE IS ONLY ONE CASTING APPARATUS PER COMPLEX. THUS ONLY ONE FILTERBOX EMISS ION SOURCE AND POINT REPRESENTS A LL FILTERBOXES IN A SINGLE CASTING COMPLEX. Building(s): 221

Air Po llution Control Permit Conditions Page 18 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Item 2.10: The facility is authorized to perform regulated processes under this permit for: Emission Unit: P-00001 Emission Unit Description: This emission unit consists of all the parts washers in the facility. Item 2.11: The facility is authorized to perform regulated processes under this permit for: Emission Unit: S-00001 Emission Unit Description: ONE POTLINE OF ELECTROLYTIC CELLS AND ASSOCIATED CONTROL EQUIPMENT. THIS POTLINE IS CATEGORIZED AS A CENTER WORK PREBAKE-1 (CWPB-1) AS DESCRIBED IN THE DEFINITIONS SECTION OF EPA'S PRIMARY ALUMINUM MACT REGULATIONS. THE PERMIT TO CONSTRUCT WAS ISSUED IN NOVEMBER 1973. Building(s): 401 402 Item 2.12: The facility is authorized to perform regulated processes under this permit for: Emission Unit: S-00002 Emission Unit Description: ANODE BAKING FURNACE AND ASSOCIATED ALUMINA INJECTION DRY SCRUBBER. Building(s): 351 Item 2.13: The facility is authorized to perform regulated processes under this permit for: Emission Unit: S-00003 Emission Unit Description: PASTE PRODUCTION PLANT AND ASSOCIATED COKE INJECTION SCRUBBER. Building(s): 354C Item 2.14: The facility is authorized to perform regulated processes under this permit for: Emission Unit: S-00004 Emission Unit Description: MATERIAL HANDLING OPERATIONS FOR ALUMINA, CARBON AND OTHER MISCELLANEOUS SOLID MATERIALS. EACH ARE CONTROLLED BY A FABRIC FILTER TO LIMIT PARTICULATE EMISSIONS TO Air Po llution Control Permit Conditions Page 19 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 THE ENVIRONMENT. Building(s): 332 344 351 354B 354C 378 380 435 440A 440E 440H 441 441C 446A 446B 446C 469 Item 2.15: The facility is authorized to perform regulated processes under this permit for: Emission Unit: S-00005 Emission Unit Description: COAL TAR PITCH UNLOADING AND STORAGE. INCLUDES FUGITIVES FROM THE PITCH UNLOADING PUMPS AND PITCH RECIRCULATING PUMPS. Building(s): 352B 352F Item 2.16: The facility is authorized to perform regulated processes under this permit for: Emission Unit: S-00006 Emission Unit Description: SMELTING AND A NODE PLANT FU GITIVES EXCEPTING POTLINE FUGITIVES (THE POTLINE FUGITIVES ARE REGULATED UNDER PRIMARY ALUMINUM MACT REGULATIONS). Building(s): 314 332 350 0351 352B 370 372 374 Air Po llution Control Permit Conditions Page 20 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 376 380 Item 2.17: The facility is authorized to perform regulated processes under this permit for: Emission Unit: W-00001 Emission Unit Description: WASTEWATER TREATMENT OPERATIONS. Building(s): 79C Condition 3: Recordkeeping and reporting of compliance monitoring Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 201-6.5(c) Item 3.1: The following information must be included in any required compliance monitoring records and reports: (i) The date, place, and time of sampling or measurements; (ii) The date(s) analyses were performed; (iii)The company or entity that performed the analyses; (iv) The analytical tec hniques or methods used incl uding quality assurance and quality control procedures if required; (v) The results of such analyses including quality assurance data where required; and (vi) The operating conditions as existing at the time of sampling or measurement. Any deviation from permit requirements must be clearly identified in all records and reports. Reports must be certified by a responsibl e official, consistent with Section 201-6.3 of this Part 201. Condition 4: Monitoring, Related Recordkeeping, and Reporting Requirements. Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 201-6.5(c)(2) Item 4.1: Compliance monitoring and recordkeepi ng shall be conducted according to the terms and conditi ons contained in this permit and shall follow all quality assurance requirements found in applicable regulations. Records of all monitoring data and support information must be retained for a period of at least 5 years from the date of the monitoring, sampling, measurement, report, or application. Support information includes all calibration and maintenance records and all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by the permit. Air Po llution Control Permit Conditions Page 21 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Condition 5: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 201-6.5(c)(3)(ii) Item 5.1: The Compliance Certification activity will be performed for the Facility. Item 5.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: To meet the requirements of this fac ility per mit with respect to reporting, the permittee must: Submit reports of any required monitoring at a minimum frequency of every 6 months, based on a calendar year reporting schedule. These reports shall be submitted to the Department within 30 days after the end of a reporting period. All instances of deviations from permit requirements must be clearly identified in such reports. All required reports must be certified by the responsible official for this facility. Notify the Department and report permit deviations and incidences of noncompliance stating the probable cause of such deviations, and any corrective actions or preventive measures taken. Where the underlying applicable requirement contains a definition of prompt or otherwise specifies a time frame for reporting deviations, that definition or time frame shall govern. Where the underlying applicable requirement fails to address the time frame for reporting deviations, reports of deviations shall be submitted to the permitting authority based on the following schedule: (1) For emissions of a h azardous air p ollutant or a toxic air pollutant (as identified in an applicable regulation) that continue fo r more than anhour in excess of permit requirements, the repo rt must be made within 24 hours of the occurrence. (2) For emissions of an y regulated air pollutant, excluding those listed in paragraph (1) of this section, that continue for more than two hours in excess of per mit requirements, the report must be made within 48 Air Po llution Control Permit Conditions Page 22 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 hours. (3) For all other deviations from permit requirements, the report shall be contained in the 6 month monitoring report required above. (4) This permit may contain a more stringent reporting requirement than required by paragraphs (1), (2) or (3) above. If more stringent reporting requirements have been placed in this permit or exist in applicable requirements that apply to this facility, the more stringent reporting requirement shall apply. If any of the above cond itions are met, the source must notify the permitting authority by telephone during normal business hours at the Regional Office of jurisdiction for

0 this permit, attention Re gional Air Pollution Control Engineer (RAP CE) according to the timetable listed in paragraphs (1) through (4) of this section. For deviations and incidences that must be reported outside of normal business hours, on weekends, or holidays, the DEC Spill Hotline phone number at 1- 800-457-7362 shall be used. A written notice, certified by a responsible official consistent with 6 NYCRR Part 201-6.3(d)(12), must be submitted within 10 working days of an occurrence for deviations reported under (1) and (2). All deviations reported under paragraph (1) t hrough (4) of this section must also be identified in the 6 month monitoring report required above. If the permittee seeks to have a violation excused as provided in 201-1.4, the perm ittee shall report such violations as required under 201-1.4(b). Ho wever, in no case may reports of any deviation be on a less frequent basis than those described in paragraphs (1) though (4) above. In order to have a violation of a federal regulation (such as a new source performance standard or national emissi ons standa rd for h azardous air p ollutants) excused, the specific federal regulation must provide for an affirmative defense during start-up, shutdowns, malfunctions or upsets. In the case of any condition contained in this permit with a reporting requirement of "Upon request by regulatory agency" the permittee shall include in the semiannual report, a statement for each such condition that the monitoring or recordkeeping was performed as required or requested and a listing of all instances of Air Po llution Control Permit Conditions Page 23 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 deviations from these requirements. In the case of any emission testing performed during the previous six month reporting period, either due to a request by the Department, EPA, or a regulatory requirement, the permittee shall include in the semiannual report a summary of the testing results and shall indicate whether or not the Department or EPA has approved the results. All semiannual reports shall be submitted to the Administrator (or his or her representative) as well as two copies to the Department (one copy to the regional air pollution control engineer (RAPCE) in the regional office and one copy to the Bureau of Compliance Monitoring and Enforcement (BCME) in the DEC central office). Mailing addresses for th e above refer enced pe rsons are contained in the monitoring condition for 6 NYCRR Part 201-6.5(e), contained elsewhere in this permit. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 6: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 201-6.5(e) Item 6.1: The Compliance Certification activity will be performed for the Facility. Item 6.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Requirements for compliance certifications with terms and conditions contained in this facility permit include the following: i. Compliance certifications shall contain: - the identification of each term or condition of the permit that is the basis of th e ce rtification; - the compliance status; Air Po llution Control Permit Conditions Page 24 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 - whether compliance was continuous or intermittent; - the method(s) used for determining the compliance status of the facility, currently and over the reporting period consistent with the monitoring and related recordkeeping and reporting requirements of this permit; - such other facts as the Department may require to determine the compliance status of the fac ility as specified in any special permit terms or conditions; and - such additional requirements as may be specified elsewhere in this perm it related to compliance certification. ii. The responsible officialmust include in the annual certification report all terms and conditions contained in this permit which are identified as being subject to certification, including emission limitations, standards, or work practices. That is, the provisi ons labeled herein as "Compliance Certification" are not the only provisi ons of this permit for which an annual certification is required. iii. Compliance certifications shall be submitted annually. Certification reports are due 30 days after the anniversary date of four consecutive calendar quarters. The first report is due 30 days after the calendar quarter that occurs just prior to the permit anniversary date, unless another quarter has been acceptable by the Department. iv. All compliance certifications shall be submitted to the Administrator (or his or her representative) as well as two copies to the Department (one copy to the regional air pollution control engineer (RAPCE) in the regional office and one copy to the Bureau of Compliance Monit oring and Enforcement (BCME) in the DEC central office). Please send annual compliance certifications to Chief of the Stationary Source Compliance Section, the Region 2 EPA representative for the Administrator, at the following address: USEPA Region 2 Air Compliance Branch 290 Broadway New York, NY 10007-1866 The address for the RAPCE is as follows:

Air Po llution Control Permit Conditions Page 25 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 State Office Building 317 Washington Street Watertown, NY 13601-3787 The address for the BCME is as follows: NYSDEC Bureau of Co mpliance Monitoring and Enforcement 625 Broadway Albany, NY 12233-3258 Monitoring Frequency: ANNUALLY Reporting Requirements: ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due on the same day each year Condition 7: Non Applicable requirements Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 201-6.5(g) Item 7.1: This section contains a summary of those requ irements that have been specifically identified as being not applicable to this facility and/or emission units, emission point s, processes and/or emission sources withinthis facility. The summary also includes a justification for classifying any such requirements as nonapplicable. 6NYCRR 212.4(c) Emission Unit: M 00001 Reason: This emission unit w ill be compl ying with the PM emission limits contained in the Secondary Aluminum Production NESHAP (40 CFR Part 63 Subpart RRR) and thus is exempt from the PM limits contained in 6 NYCRR Part 212.4(c) as allowed by 6 NYCRR Part 212.5(d). 6NYCRR 212.4(c) Emission Unit: M 00002 Reason: This emission unit w ill be compl ying with the PM emission limits contained in the Secondary Aluminum Production NESHAP (40 CFR Part 63 Subpart RRR) and thus is exempt from the PM limits contained in 6 NYCRR Part 212.4(c) as allowed by 6 NYCRR Part 212.5(d). 6NYCRR 225-1.7(b) Emission Unit: B 00001 Process: OIL Reason: The requirement for a SO2 CEMS does not apply since Alcoa meets the exception contained in 6 NY CRR Part Air Po llution Control Permit Conditions Page 26 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 225-1.7(b)(2) by virtue of performing the sampling and recordkeeping contained in the permit condition cited 6 NYCRR Part 225-1.8(a). 6NYCRR 228.1(a) Emission Unit: A 00002 Emission Point: F0031 Process: MRS Source: AF031 Reason: This source is exempt from permitting requirements per 6 NYCRR Part 201-3.3(c)(45). As such the VOC RACT requirements of 6 NYCRR Part 228 for surf ace coating processes do not apply. 6NYCRR 228.1(a) Emission Unit: A 00002 Emission Point: F0065 Process: MRS Source: AF065 Reason: This source is exempt from permitting requirements per 6 NYCRR Part 201-3.3(c)(45). As such the VOC RACT requirements of 6 NYCRR Part 228 for surf ace coating processes do not apply.

Condition 8: Required Emissions Tests - Facility Level Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 202-1.1 Item 8.1: An acceptable report of measured emissi ons shall be submitted, as required by the c ommission er, to ascertain compliance or noncompliance with any air pollution code, rule, or regulation. Condition 9: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 202-2.1 Item 9.1: The Compliance Certification activity will be performed for the Facility. Item 9.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Emission statements shall be submitted on or before April 15th each year for emissions of the previous calendar p0 year. Monitoring Frequency: ANNUALLY Reporting Requirements: ANNUALLY (CALENDAR) Reports due by April 15th for previous calendar year Air Po llution Control Permit Conditions Page 27 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Condition 10: Recordkeeping requirements Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 202-2.5 Item 10.1: (a) The follow ing records shall be maintained for at least five y ears: (1) a copy of each emission statement submitted to the department; and (2) records indicating how the information submitted in the emission statement was determined, including any calculations, data, measurements, and estimates used. (b) These records shall be made available at the fac ility to the representatives of the department upon request during normal business hours. Condition 11: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212. Item 11.1: The Compliance Certification activity will be performed for the Facility. Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 11.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: All sources that employ control devices to limit particulate emissi ons, shall be monitored and maintained according to the Operation and Maintenance (O & M) plan submitted and approved by the Department in order to insure proper operation and control. The O & M plan shall be considered a " living" document and w ill be changed and improved over time. Each change shall be submitted to the department for approval. Exceedances of the proper operating limits shall be re ported semi -annually. Records shall be maintained for a minimum of five years.
Compliance testing will be done upon request from the Department.

Air Po llution Control Permit Conditions Page 28 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Reference Test Method: EPA Method 5 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 12: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.4(c) Item 12.1: The Compliance Certification activity will be performed for the facility: The Compliance Certification applies to: Emission Unit: A- 00002 Emission Unit: S- 00004 Emission Unit: A- 00001 Process: EPH Emission Unit: A- 00001 Process: HMO Emission Unit: A- 00001 Process: HT1 Emission Unit: C- 00001 Process: CD1 Emission Unit: C- 00001 Process: CM1 Emission Unit: D- 00001 Process: ALB Emission Unit: D- 00001 Process: SKD Emission Unit: S- 00002 Process: BAK Emission Unit: A- 00001 Process: HT2 Emission Source: AF014 Emission Unit: A- 00001 Air Po llution Control Permit Conditions Page 29 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Process: HT2 Emission Source: AF015 Emission Unit: A- 00001 Process: HT2 Emission Source: AF02A Emission Unit: A- 00001 Process: HT2 Emission Source: AF02B Emission Unit: C- 00002 Process: CD2 Emission Source: C0044 Emission Unit: C- 00002 Process: CM2 Emission Source: C0045 Emission Unit: S- 00003 Emission Point: S0100 Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 12.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: Emissions of solid particulates are limited to less than 0.050 grains of particulates per cubic foot of exhaust gas expressed at standard conditions on a dry gas basis. Compliance testing shall be conducted upon request from the department. Upper Permit Limit: 0. 050 grains per dscf Reference Test Method: EPA Method 5 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY 

### i0 Condition 13: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.6(a) Item 13.1: The Compliance Certification activity will be performed for the facility: The Compliance Certification applies to:

Air Po llution Control Permit Conditions Page 30 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Emission Unit: S- 00004 Emission Unit: S- 00005 Emission Unit: S- 00003 Emission Point: S0100 Emission Unit: A- 00001 Process: EPH Emission Unit: A- 00001 Process: HMO Emission Unit: A- 00001 Process: HT1 Emission Unit: D- 00001 Process: ALB Emission Unit: D- 00001 Process: CCT Emission Unit: D- 00001 Process: SKD Emission Unit: A- 00001 Process: HT2 Emission Source: AF014 Emission Unit: A- 00001 Process: HT2 Emission Source: AF015 Emission Unit: A- 00001 Process: HT2 Emission Source: AF02A Emission Unit: A- 00001 Process: HT2 Emission Source: AF02B Emission Unit: W- 00001 Emission Unit: C- 00001 Process: CD1 Emission Unit: C- 00002 Process: CD2 Emission Unit: F- 00001 Process: FB1 Emission Unit: F- 00001 Air Po llution Control Permit Conditions Page 31 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Process: FB2 Emission Unit: F- 00001 Process: FB3 Emission Unit: F- 00001 Process: FC1 Emission Unit: F- 00001 Process: FC2 Emission Unit: A- 00002 Emission Unit: M- 00001 Emission Unit: M- 00002 Emission Unit: C- 00001 Process: CM1 Emission Unit: C- 00002 Process: CM2 Emission Unit: F- 00001 Process: FC3 Emission Unit: S- 00006 Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 13.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: No person will cause or allow emissions having an average opacity during any six consecutive minutes of 20 percent or greater from any process emission source, except only the emission of uncombined water. The department reserves the right to perform or require the performance of a method 9 opacity evaluation at any time during facility operation. Upper Permit Lim it: 20 percent Reference Test Method: EPA Method 9 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Air Po llution Control Permit Conditions Page 32 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 14: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.10(c)(1) Item 14.1: The Compliance Certification activity will be performed for the facility: The Compliance Certification applies to: Emission Unit: A- 00001 Process: HMO Emission Unit: S- 00001 Process: POT Emission Unit: A- 00001 Emission Point: I0014 Emission Unit: A- 00001 Emission Point: I015A Emission Unit: A- 00001 Emission Point: I015B Emission Unit: A- 00001 Emission Point: F0075 Emission Unit: A- 00001 Emission Point: F0076 Emission Unit: A- 00001 Emission Point: F074A Emission Unit: A- 00001 Emission Point: F074B Emission Unit: A- 00001 Emission Point: F0014 Emission Unit: A- 00001 Emission Point: F0015 Emission Unit: A- 00001 Emission Point: F001A Emission Unit: A- 00001 Emission Point: F001B Emission Unit: A- 00001 Emission Point: F001C Emission Unit: A- 00001 Emission Point: F001D Emission Unit: A- 00001 Emission Point: F001E Emission Unit: A- 00001 Emission Point: F002A Air Po llution Control Permit Conditions Page 33 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Unit: A- 00001 Emission Point: F002B Emission Unit: A- 00001 Emission Point: I0026 Emission Unit: A- 00001 Emission Point: I0027 Emission Unit: A- 00001 Emission Point: I0043 Emission Unit: A- 00001 Emission Point: I0046 Emission Unit: M- 00001 Emission Point: I001A Emission Unit: M- 00001 Emission Point: I001B Emission Unit: M- 00001 Emission Point: I001C Emission Unit: M- 00001 Emission Point: I001D Emission Unit: M- 00001 Emission Point: I0034 Emission Unit: M- 00001 Emission Point: I0035 Emission Unit: M- 00001 Emission Point: I003A Emission Unit: M- 00001 Emission Point: I003C Emission Unit: M- 00001 Emission Point: I024C Emission Unit: M- 00001 Emission Point: I024D Emission Unit: A- 00002 Emission Point: F0067 Regulated Contaminant(s): CAS No: 0NY210-00-0 OXIDES OF NITROGEN Item 14.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: The emission rate potential of oxides of nitrogen (NOx) from each emission point shall remain less than 3.0 pounds per hour. A reasonably available control technology (RACT) analysis is not required for emission points with NOx emission rate potentials less than 3.0 pounds per hour at facilities located outside the lower Orange County and New York City metropolitan areas. Compliance testing shall be Air Po llution Control Permit Conditions Page 34 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 conducted upon request from the Department. Upper Permit Limit: 3. 0 pounds per hour Reference Test Method: EPA Method 7 Monitoring Frequency: SINGLE OCCURRENCE Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 15: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.10(c)(1) Item 15.1: The Compliance Certification activity will be performed for the facility: The Compliance Certification applies to: Emission Unit: A- 00001 Emission Point: F0014 Emission Unit: A- 00001 Process: HT1 Emission Unit: A- 00001 Emission Point: F0015 Emission Unit: A- 00001 Emission Point: F002A Emission Unit: A- 00001 Emission Point: F002B Emission Unit: S- 00005 Process: PUN Emission Unit: W- 00001 Process: OWT Emission Unit: W- 00001 Process: WWT Emission Unit: F- 00001 Emission Unit: A- 00002 Emission Point: F0067 Regulated Contaminant(s): CAS No: 0NY998-00-0 VOC Item 15.2: Compliance Certification shall include the following monitoring:

Air Po llution Control Permit Conditions Page 35 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: The emission rate potential of Volatile O rganic Comp ounds (VOCs) from each emission point shall remain less than 3.0 pounds per hour. A reasonably available control technology (RACT) analysis is not required for emission points with VOC emission rate potentials less than 3.0 pounds per hour at facilities located outside the lower Orange County and New York City metropolitan areas. Compliance testing shall be conducted upon request from the Department. Upper Permit Limit: 3. 0 pounds per hour Reference Test Method: EPA Method 7E Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 16: Equipment Specifications for Cold Cleaning Batch Degreasing Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 226. Item 16.1: A. Equipment specifications: 1. A cover shall be provided which can be operated easily. 2. The drainage facility shall be internal (under cover), if practical. 3. A control system that limits VOC emissions to those achievable with equipment having a freeboard ratio greater than or equal to 0.7, or a water cover where the s olvent is insoluble in and heavier than water, where the solvent being used has a vapor pressure greater than 33mm Hg at 38 o C (100 o F) or where the solvent is heated above 50 o C (120 o F) B. Operating requirements: 1. Clean parts shall be drained at least 15 seconds or until dripping ceases. C. General requirements: No person shall conduct solvent metal cleaning unless: 1. Solvent is stored in covere d containers and waste solvent is transferred or disposed of in such a manner that less than 20 percent of the waste solvent (by weight) can evaporate into the atmosphere. 2. Equipment used in solvent metal cleaning is maintained to minimize leaks and fugitive emissions. 3. Equipment used in solvent metal cleaning displays a conspicuous summary of p roper operating procedures consistent with minimizi ng emissions of volatile organic comp ounds.

Air Po llution Control Permit Conditions Page 36 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 4. Equipment covers are closed when the solvent metal cleaning unit is not in service. 5. A record of solvent consumption shall be maintained for each year and made available to the commissioner or his representative upon request.

Condition 17: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.3(a) Item 17.1: The Compliance Certification activity will be performed for the facility: The Compliance Certification applies to: Emission Unit: A- 00001 Emission Point: F078A Emission Unit: A- 00001 Emission Point: F078B Emission Unit: A- 00001 Emission Point: FC01A Emission Unit: A- 00001 Emission Point: FC01B Emission Unit: A- 00001 Emission Point: FC01C Emission Unit: A- 00001 Emission Point: FC01D Emission Unit: A- 00001 Emission Point: FC01E Emission Unit: B- 00001 Process: OIL Emission Source: B0001 Emission Unit: B- 00001 Process: OIL Emission Source: B0002 Emission Unit: B- 00001 Process: OIL Emission Source: B0003 Emission Unit: B- 00001 Process: OIL Emission Source: B0004 Emission Unit: B- 00001 Emission Point: 00001 Process: GAS Emission Unit: B- 00001 Emission Point: 00002 Process: GAS Item 17.2: Compliance Certification shall include the following monitoring: Air Po llution Control Permit Conditions Page 37 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: No owner or o perator of a c ombustion installation shall emit greater than 20 percent opacity except for one six minute period per hour, not to exceed 27 percent, based upon the six minute average in reference test method 9 in appendix A of 40 CFR 60. Testing shall be conducted upon request from the Department. Parameter Monitored: OPACITY Upper Permit Lim it: 20 percent Reference Test Method: EPA Method 9 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: 6-MINUTE AVERAGE (METHOD 9) Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 18: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-2.4(g)(3) Item 18.1: The Compliance Certification activity will be performed for the facility: The Compliance Certification applies to: Emission Unit: A- 00001 Emission Point: F078A Emission Unit: A- 00001 Emission Point: F078B Emission Unit: A- 00001 Emission Point: FC01A Process: HT1 Emission Unit: A- 00001 Emission Point: FC01B Process: HT1 Emission Unit: A- 00001 Emission Point: FC01C Process: HT1 Emission Unit: A- 00001 Emission Point: FC01D Process: HT1 Emission Unit: A- 00001 Emission Point: FC01E Process: HT1 Regulated Contaminant(s): Air Po llution Control Permit Conditions Page 38 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 CAS No: 0NY210-00-0 OXIDES OF NITROGEN Item 18.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: A RACT analysis is not necessary for sources that emit less than 3 lbs per hour of oxides of nitrogen. Testing shall be conducted upon request from the department to ensure compliance. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 19: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 257-8. Item 19.1: The Compliance Certification activity will be performed for the Facility. Regulated Contaminant(s): CAS No: 068188-85-2 FLUORIDES Item 19.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Standards. a) Total Fluorides, part per million (ppm), dry weight basis (as F) in and on forage for consumption for grazing ruminants. Average concentration shall be less than the following in all levels: (1) For growing season ( not to exceed six consecutive months)-40 ppm (2) For any 60 day period- 60 ppm (3) For any 30 day period- 80 ppm Measurement. (a) Total Fluorides in and on forage is determined by fusion of a representative sample by the Schoniger flash oxygen comb ustion method and anal ysis by specific ion electrode or other methods acceptable to the commissioner.

Air Po llution Control Permit Conditions Page 39 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Alcoa shall continue Fluoride testing and reporting in accordance with the" Work/Qua lity Assurance Project PlanSampling and Anlysis for Fluoride in Vegetation" dated May 5, 1999. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 20: Incorporation by Reference Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.841, Subpart LL Item 20.1:

(a) The following material is incorporated by reference in the corresponding sections noted. This incorporation by reference was approved by the Director of the Federal Register on October 7, 1997, in accordance with 5 U.S.C. 552(a) and 1 CFR Part 51. These materials are incorporated as they exist on the date of approval, and notice of any change in the materials w ill be publi shed in the Federal Register. Revisions to ``Industrial Ventilation: A Manual of Recommended Practice'' (22nd ed.) are applicable only after publication of a document in the Federal Register to amend subpart LL to require use of the new information. (1) Chapter 3, ``Local Exhaust Hoods'' and Chapter 5, ``Exhaust System Design Procedure'' of ``Industrial Ventilation: A Manual of Recomme nded Practice,'' American Conference of Governmental Industrial Hygienists, 22nd edition, 1995, IBR approved for 40 CFR Part 63.843(b) and 40 CFR Part 63.844(b); and (2) ASTM D 2986-95A, Standard Practice for Evaluation of Air Assay Media by the Monodisperse DOP (Dioctyl Phthalate) Smoke Test, IBR approved for section 7.1.1 of Method 315 in appendix A to 40 CFR Part 63. (b) The materials incorporated by reference are available for inspection at the Office of the Federal Register, 800 North Capitol Street NW., Suite 700, 7th Floor, Washington, DC, and at the Air and Radiation Docket Center, U.S. EPA, 401 M Street, SW., Washington, DC. The materials also are available for purchase from one of the following addresses: (1) Customer Service Department, American Conference of Governmental Industrial Hygienists (ACGIH), 1330 Kemper Meadow Drive, Cincinnati, Ohio 45240, telep hone number (513) 742- 2020; or (2) American Society for Testing and Materials, 100 Bar Harbour Drive, West Cons hohocken, Pennsylvania 19428, telep hone number (610) 832- 9500.

Air Po llution Control Permit Conditions Page 40 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Condition 21: Compliance Provisions - Test Plan Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(b) , Subpart LL Item 21.1: The owner or operator shall prepare a site-sp ecific test plan prior to th e initial perfor mance test according to the requirements of 40 CFR Part 63.7(c). The test plan must include procedures for conducting the initial performance test and fo r subsequent performance tests required in 40 CFR Part 63. 848 for emission monitoring. In addition to the information re quired by 40 CFR Part 63.7, the test plan shall include:

(1) Procedures to ensure a minimum of t hree runs are performed annually for the primary control system for each source; (2) For a source with a single control device e xhausted through multiple st acks, procedures to ensure that at least three runs are performed annually by a representative sample of the stacks satisfactory to the applicable regulatory authority; (3) For multiple control devices on a single source, procedures to ensure that at least one run is performed annually for each control device by a repr esentative sample of the stacks satisfactory to the applicable regulatory authority; (4) Procedures for sampling single stack s associated with multiple anode bake furn aces; (8) Procedures for establishing the frequency of testing to ensure that at least one run is performed before the 15th of the month, at least one run is performed after the 15th of the month, and that there are at least 6 d ays between two of the runs during the m onth, or that s econdary emissions are measured according to an alternate schedule sa tisfactory to the applicable regulatory authority. Condition 22: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848, Subpart LL Item 22.1: The Compliance Certification activity will be performed for the facility: The Compliance Certification applies to: Emission Unit: S- 00001 Process: POT Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s):

Air Po llution Control Permit Conditions Page 41 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 CAS No: 0NY505-00-0 40 CFR 63 SUBPART LL - POM CAS No: 068188-85-2 FLUORIDES Item 22.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator shall install, operate, calibrate, and maintain a conti nuous parameter monitoring system for each emission control device. The owner/operator shall submit for approval by the New York State DEC a description of the parameter(s) to be monitored, the operating limits, and the monitoring frequency to ensure that the control device is being properly operated and maintained. An explanation of the criteria used for selection of the parameter(s), the operating limits, and the monitoring frequency, including how t hese relate to emission control also shall be submitted to the New York State DEC.

Reference Test Method: EPA 13A or ALT, 315 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 23: Reference test methods for TF and POM emissions Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.849(a) , Subpart LL Item 23.1: The owner/operator shall use the following refe rence methods to determine compliance with the applicable emission limits for TF and POM emissions: 1) Method 1 in Appendix A to part 60 for sample and velocity traverses; 2) Method 2 in Appendix A to part 60 for velocity and volumetric flow rate; 3) Method 3 in Appendix A to part 60 for gas analysis; 4) Method 13A or 13B in Appendix A to part 60, or an approved alternative, for the concentration of TF where stack or duct emission are sampled; 5) Method 13A or 13B and Method 14 or 14A in Appendix A to part 60 or an approved alternative method for the concentration of TF where emissions are sampled from roof monitors not employing wet roof scrubbers; 6) Method 315 in Appendix A to part 63 or an approved alternative method for the concentration of POM where stack or duct emissions are sampled; and Air Po llution Control Permit Conditions Page 42 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 7) Method 315 in Appendix A to part 63 and Met hod 14 in Appendix A to part 60 or an approved alternative method for the concentration of POM where emissions are sampled from roof monitors not employing wet roof scrubbers. Condition 24: Alternative test methods for TF or POM emissions Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.849(e) , Subpart LL Item 24.1: The owner/operator may use an alternative test method for TF or POM emissions providing: 1) The owner/operator has already demonstrated the equivalency of the alt ernative method fo r a specific plant and has received previous approval from the Administrator or the New York State DEC for TF or POM measurements using the alternative methods; or 2) The owner/operator demonstrates to the satisfac tion of the New York State DEC that the results from the alternative met hod meet the criteria specified in §§63. 848(d)(1) and (d)(3) through (d)(6). The re sults from the alternative method shall be based on sim ultaneous sampling using the alternative method and the following reference methods: For TF, Methods 13 and 14 or Method 14A in appendix A to part 60, or for POM, Method 315 in appendix A to part 63 and Method 14 in appendix A to part 60. Condition 25: Accidental release provisions. Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 68. Item 25.1: If a chemical is listed in Tables 1,2,3 or 4 of 40 CFR §68. 130 is present in a pr ocess in quantities g reater than the threshold quantity listed in Tabl e 1, the following requirements will apply: a) The owner or operator shall comply with the provisions of 40 CFR Part 68 and; b) The owner or operator shall submit (if not previ ously submitted) one of the following if such quantities are present at the time of permit issuance: 1) A compliance schedule for meeting the requirem ents of 40 CFR Part 68 by the date provided in 40 CFR §68.10(a) or, 2) A certification statement that the source is in compliance with all requirements of 40 CFR Part 68, including the registration and submission of th e Risk Manageme nt Plan. Information should be submitted to: USEPA Region 2 Air Compliance Branch 290 Broadway Air Po llution Control Permit Conditions Page 43 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 New York, NY 10007-1866 ATTN: Accidental Release Program contact Condition 26: Recycling and Emissions Reduction Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 82, Subpart F Item 26.1: The permittee shall comply with all a pplicable provisions of 40 CFR Part 82.

** ** Emission Unit Level   Condition 27: Emission Point Definition By Emission Unit Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 201-6. Item 27.1: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: A-00001 Emission Point: F0014 Height (ft.): 41 Diameter (in.): 25 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 140 Emission Point: F0015 Height (ft.): 48 Diameter (in.): 25 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 140 Emission Point: F001A Height (ft.): 50 Diameter (in.): 24 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: F001B Height (ft.): 50 Diameter (in.): 24 

### rd NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131
Emission Point: F001C Height (ft.): 50 Diameter (in.): 24 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: F001D Height (ft.): 50 Diameter (in.): 24 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131

Air Po llution Control Permit Conditions Page 44 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Point: F001E Height (ft.): 50 Diameter (in.): 24 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: F002A Height (ft.): 47 Diameter (in.): 21 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 140 Emission Point: F002B Height (ft.): 47 Diameter (in.): 21 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 140 Emission Point: F0075 Height (ft.): 47 Diameter (in.): 12 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: F0076 Height (ft.): 46 Diameter (in.): 21 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: F074A Height (ft.): 45 Diameter (in.): 12 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: F074B Height (ft.): 45 Diameter (in.): 12 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: F078A Height (ft.): 42 Diameter (in.): 24 Building: 140 Emission Point: F078B Height (ft.): 42 Diameter (in.): 24 Building: 140 Emission Point: FC01A Height (ft.): 50 Diameter (in.): 10 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: FC01B Height (ft.): 50 Diameter (in.): 24 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: FC01C Height (ft.): 50 Diameter (in.): 24 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Air Po llution Control Permit Conditions Page 45 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Point: FC01D Height (ft.): 50 Diameter (in.): 24 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: FC01E Height (ft.): 50 Diameter (in.): 10 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: I0014 Height (ft.): 52 Diameter (in.): 42 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 234 Emission Point: I0026 Height (ft.): 62 Diameter (in.): 54 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 222 Emission Point: I0027 Height (ft.): 62 Diameter (in.): 54 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 222 Emission Point: I0043 Height (ft.): 52 Diameter (in.): 54 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 222 Emission Point: I0046 Height (ft.): 62 Diameter (in.): 54 Building: 222 Emission Point:n0 I015A Height (ft.): 52 Diameter (in.): 42 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 234 Emission Point: I015B Height (ft.): 52 Diameter (in.): 42 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 234 Item 27.2: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: A-00002 Emission Point: F0031 Height (ft.): 20 Diameter (in.): 24 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: F0062 Height (ft.): 10 Length (in.): 12 Width (in.): 12 Air Po llution Control Permit Conditions Page 46 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 140 Emission Point: F0063 Height (ft.): 8 Diameter (in.): 7 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: F0064 Height (ft.): 30 Diameter (in.): 12 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: F0065 Height (ft.): 7 Diameter (in.): 12 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Emission Point: F0067 Height (ft.): 26 Diameter (in.): 8 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 131 Item 27.3: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: B-00001 Emission Point: 00001 Height (ft.): 60 Diameter (in.): 96 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 216A Emission Point: 00002 Height (ft.): 60 Diameter (in.): 96 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 216A Item 27.4: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: C-00001 Emission Point: I0029 Height (ft.): 52 Diameter (in.): 36 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 221 Emission Point: I0030 Height (ft.): 73 Diameter (in.): 42 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 221 Item 27.5: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: C-00002 Air Po llution Control Permit Conditions Page 47 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Point: I0044 Height (ft.): 74 Diameter (in.): 36 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 221 Emission Point: I0045 Height (ft.): 74 Diameter (in.): 44 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 221 Item 27.6: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: D-00001 Emission Point: F0042 Height (ft.): 57 Diameter (in.): 19 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 140 Emission Point: I0016 Height (ft.): 52 Diameter (in.): 42 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 220 Emission Point: I0042 Height (ft.): 50 Diameter (in.): 22 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 222 Item 27.7: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: M-00001 Emission Point: I001A Height (ft.): 67 Diameter (in.): 32 Building: 221 Emission Point: I001B Height (ft.): 67 Diameter (in.): 32 Building: 221 Emission Point: I001C Height (ft.): 68 Diameter (in.): 20 Building: 221 Emission Point: I001D Height (ft.): 68 Diameter (in.): 20 Building: 221 Emission Point: I0034 Air Po llution Control Permit Conditions Page 48 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Height (ft.): 74 Diameter (in.): 32 Building: 221 Emission Point: I0035 Height (ft.): 74 Diameter (in.): 32 Building: 221 Emission Point: I003A Height (ft.): 67 Diameter (in.): 33 Building: 221 Emission Point: I003C Height (ft.): 67 Diameter (in.): 79 Building: 221 Emission Point: I024C Height (ft.): 74 Diameter (in.): 50 Building: 221 Emission Point: I024D Height (ft.): 74 Diameter (in.): 50 Building: 221 Emission Point: I024F Height (ft.): 82 Diameter (in.): 79 Building: 221 Item 27.8: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: M-00002 Emission Point: 10036 Height (ft.): 52 Diameter (in.): 9 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 221 Emission Point: 1024E Height (ft.): 46 Diameter (in.): 8 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 221 Emission Point: I001E Height (ft.): 67 Diameter (in.): 42 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 221 Emission Point: I003E Height (ft.): 48 Diameter (in.): 8 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 221

Air Po llution Control Permit Conditions Page 49 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Item 27.9: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: S-00001 Emission Point: SA398 Height (ft.): 78 Diameter (in.): 48 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 401 Item 27.10: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: S-00002 Emission Point: S0078 Height (ft.): 105 Diameter (in.): 84 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 351 Emission Point: SS078 Height (ft.): 105 Diameter (in.): 84 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 351 Item 27.11: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: S-00003 Emission Point: S0100 Height (ft.): 111 Diameter (in.): 42 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 354C Item 27.12: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: S-00004 

### Emission Point: S0015 Height (ft.): 19 Length (in.): 12 Width (in.): 12 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 332 Emission Point: S0016 Height (ft.): 23 Length (in.): 12 Width (in.): 12 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 332 Emission Point: S0017 Height (ft.): 62 Diameter (in.): 25 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 332

Air Po llution Control Permit Conditions Page 50 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Point: S0038 Height (ft.): 15 Diameter (in.): 33 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 354B Emission Point: S0041 Height (ft.): 42 Diameter (in.): 15 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 441 Emission Point: S0043 Height (ft.): 91 Diameter (in.): 15 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 441C Emission Point: S0046 Height (ft.): 79 Diameter (in.): 10 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 446A Emission Point: S0047 Height (ft.): 79 Diameter (in.): 10 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 446B Emission Point: S0048 Height (ft.): 79 Diameter (in.): 10 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 446C Emission Point: S0049 Height (ft.): 106 Diameter (in.): 15 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 354C Emission Point: S0050 Height (ft.): 106 Diameter (in.): 15 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 354C Emission Point: S0051 Height (ft.): 106 Diameter (in.): 13 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 354C Emission Point: S0052 Height (ft.): 106 Diameter (in.): 21 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 354C Emission Point: S0053 Height (ft.): 106 Diameter (in.): 13 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 354C Emission Point: S0060 Height (ft.): 105 Diameter (in.): 16 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 354C Air Po llution Control Permit Conditions Page 51 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Point: S0061 Height (ft.): 105 Diameter (in.): 9 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 354C Emission Point: S0083 Height (ft.): 5 Diameter (in.): 21 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 344 Emission Point: S0086 Height (ft.): 22 Diameter (in.): 15 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 440A Emission Point: S0090 Height (ft.): 4 Length (in.): 13 Width (in.): 11 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 378 Emission Point: S0092 Height (ft.): 63 Length (in.): 22 Width (in.): 19 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 440E Emission Point: S0093 Height (ft.): 166 Length (in.): 18 Width (in.): 24 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 440E Emission Point: S0095 Height (ft.): 28 Length (in.): 23 Width (in.): 19 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 351 Emission Point: S0102 Height (ft.): 27 Diameter (in.): 52 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 469 Emission Point: S023B Height (ft.): 35 Diameter (in.): 52 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 380 Emission Point: S23AA Height (ft.): 40 Diameter (in.): 75 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 435 Emission Point: S23AC Height (ft.): 17 Diameter (in.): 27 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 435 Item 27.13: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: S-00005 Air Po llution Control Permit Conditions Page 52 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Point: S0073 Height (ft.): 37 Diameter (in.): 8 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 352B Emission Point: S0077 Height (ft.): 37 Diameter (in.): 8 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 352B Emission Point: S0088 Height (ft.): 28 Diameter (in.): 12 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 352F Emission Point: S0089 Height (ft.): 28 Diameter (in.): 12 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 352F Emission Point: S073A Height (ft.): 37 Diameter (in.): 8 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 352B Item 27.14: The following emission points are included in this permit for the cited Emission Unit: Emission Unit: W-00001 Emission Point: F0068 Height (ft.): 40 Diameter (in.): 3 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 79C Emission Point: F0069 Height (ft.): 41 Diameter (in.): 14 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 79C Emission Point: F0070 Height (ft.): 41 Diameter (in.): 12 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 79C Emission Point: F0071 Height (ft.): 41 Diameter (in.): 10 NYTMN (km.): 4977. NYTME (km.): 508.9 Building: 79C Condition 28: Process Definition By Emission Unit Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 201-6. Item 28.1: Air Po llution Control Permit Conditions Page 53 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: A- 00001 Process: EPH Source Classification Code: 2-02-002-02 Process Description: TWO (2) 6500 TON PRESS PRE- HEATS AND ONE (1) 5300 TON PRESS PRE- HEAT FURNA CE. EACH USES MULTIPLE DIRECT FIRE NATURAL GAS BURNERS. Emission Source/Control: AI014 - Process Emission Source/Control: AI15A - Process Emission Source/Control: AI15B - Process Item 28.2: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: A- 00001 Process: HMO Source Classification Code: 2-02-002-02 Process Description: FOUR (4) HOMOGENIZING HEAT TREAT FURNACES. EACH USES MULTIPLE DIRECT FIRE NATURAL GAS BURNERS. CHEMICAL ADDITIVE PREVENTS OXIDATION OF SURFACE OF METAL AND PRODUCES INCIDENTAL HYDROGEN FLUORIDE EMISSIONS AS A BY-PRODUCT. Emission Source/Control: AI026 - Process Emission Source/Control: AI027 - Process Emission Source/Control: AI043 - Process Emission Source/Control: AI046 - Process Design Capacity: 30 million Btu per hour Item 28.3: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: A- 00001 Process: HT1 Source Classification Code: 2-02-002-02 Process Description: #30, 31, 32, 33, 34, 35, 36, 37, 38 HEAT TREAT FURNACES PROCESS EXHAU ST. EACH FURNACE EXHAU STS THROUGH THEIR OWN EMISSION POINT. #32-36 FURNACES ARE INDIRECTLY FIRED AND HAVE SEPARATE COMBUSTION Air Po llution Control Permit Conditions Page 54 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 EXHAUSTS. RESIDUAL OIL ON ALUMINUM PRODUCES SLIGHT VOC E MISSION. CHEMICAL ADDITIVE PREVENTS OXIDATION OF SURFACE OF METAL AND PRODUCES INCIDENTAL HYDROGEN FLUORIDE EMISSION AS A BY-PRODUCT. Emission Source/Control: AFC1A - Combustion Emission Source/Control: AFC1B - Combustion Emission Source/Control: AFC1C - Combustion Emission Source/Control: AFC1D - Combustion Emission Source/Control: AFC1E - Combustion Emission Source/Control: AF01A - Process Emission Source/Control: AF01B - Process Emission Source/Control: AF01C - Process Emission Source/Control: AF01D - Process Emission Source/Control: AF01E - Process Emission Source/Control: AF075 - Process Emission Source/Control: AF076 - Process Emission Source/Control: AF74A - Process Emission Source/Control: AF74B - Process Item 28.4: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: A- 00001 Process: HT2 Source Classification Code: 2-02-002-02 Process Description: HEAT TREAT FURNACES #13, #14 AND #15 ARE INDIRECT FIRED NATURAL GAS FURNACES W HERE THE PRODUCTS OF COMBUSTION EXHAUST THR OUGH EMISSION POINT (EP) F078A. THE FURNACE IS EXHAUSTED THROUGH EP F0014. HEAT TREAT FURNACES #16, #17 AND #18 HAVE A SIMILAR ARRANGEMENT WHERE THE PRODUCTS OF COMBUSTION EXHAUST THROUGH EP F078B AND THE Air Po llution Control Permit Conditions Page 55 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 FURNACE EXHAUST THROUGH EP F0015. FURNACE PROCESS EMISSIONS CONSIST OF RESIDUAL DRAWING LUBE FROM THE BARS WHICH ARE COMBUSTED AND VAPORIZED DURING THE BEGINNING OF THE HEAT TREAT PROCESS. CHEMICAL ADDITIVES PREVENT THE OXIDATION OF SURFACE METAL. THIS ADDITIVE PRODUCES INCIDENTAL HYDROGEN FLUORIDE AS A BY-PRODUCT. NUMBER 23 AND 24 AGE ANNEAL FURNACES ARE EACH EXHAU STED THROUGH THEIR OWN EMISSION POINTS. THESE FURNACES ARE DIRECT FIRED, NATURAL GAS AND RESIDUAL OIL ON THE ALUMINUM PRODUCES SLIGHT VOC EMISSIONS. Emission Source/Control: AF014 - Process Emission Source/Control: AF015 - Process Emission Source/Control: AF02A - Process Emission Source/Control: AF02B - Process Emission Source/Control: AF78A - Process Emission Source/Control: AF78B - Process Item 28.5: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: A- 00002 Process: FAB Source Classification Code: 2-02-002-02 Process Description: Small crucible located in the Fabricating Shop used occasionally to melt lead, lead bismuth, zinc or tin babbit. Cruce heated by natural gas fired burner. Emission Source/Control: AF062 - Process Item 28.6: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: A- 00002 Process: MRS Source Classification Code: 2-02-002-02 Process Description: THREE (3) SMALL NATURAL GAS OVENS AND TWO (2) MAINTENANCE PAINTING ROOMS USED IN MAINTENANCE SHOPS. THE BAKE OVEN AND DRYING Air Po llution Control Permit Conditions Page 56 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 OVEN ARE USED TO DRY PARTS WASHED WITH A WATER BASED SOLUTION, AND OCCASIONALLY TO CURE MOTOR COILS COATED WITH VARNISH. Emission Source/Control: AF031 - Process Emission Source/Control: AF063 - Process Emission Source/Control: AF064 - Process Emission Source/Control: AF065 - Process Emission Source/Control: AF067 - Process Item 28.7: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: B- 00001 Process: GAS Source Classification Code: 2-02-002-02 Process Description: FOUR VIRTUALLY IDENTICAL BOILERS CAPABLE OF BURNING NATURAL GAS. Emission Source/Control: B0001 - Combustion Emission Source/Control: B0002 - Combustion Emission Source/Control: B0003 - Combustion Emission Source/Control: B0004 - Combustion Item 28.8: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: B- 00001 Process: OIL Source Classification Code: 1-02-004-01 Process Description: FOUR VIRTUALLY IDENTICAL BOILERS CAPABLE OF BURNING NO. 6 FUEL OIL. Emission Source/Control: B0001 - Combustion Emission Source/Control: B0002 - Combustion Emission Source/Control: B0003 - Combustion Emission Source/Control: B0004 - Combustion

Air Po llution Control Permit Conditions Page 57 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Item 28.9: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: C- 00001 Process: CD1 Source Classification Code: 3-04-001-09 Process Description: CHIP DRYER #1 DRIES ALUMINUM MACH INING CHIPS WITH HEATED AIR. Emission Source/Control: C029A - Control Control Type: SINGLE CYCLONE Emission Source/Control: C029B - Control Control Type: DIRECT FLAME AFTERBURNER Emission Source/Control: C0029 - Process Item 28.10: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: C- 00001 Process: CM1 Source Classification Code: 3-04-001-03 Process Description: CHIP MELTER #1 MELTS CLEAN ALUMINUM MACHINING CHIPS. Emission Source/Control: C0030 - Process Item 28.11: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: C- 00002 Process: CD2 Source Classification Code: 3-04-001-09 Process Description: CHIP DRYER #2 DRIES ALUMINUM MACH INING CHIPS HEATED WITH AIR. Emission Source/Control: C044A - Control Control Type: MULTIPLE CYCLONE W/O FLY ASH INJECTION Emission Source/Control: C044B - Control Control Type: THERMAL OXIDATION Emission Source/Control: C0044 - Process Item 28.12: This permit authorizes the following regul ated processes for the cited Emission Unit:

Air Po llution Control Permit Conditions Page 58 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Emission Unit: C- 00002 Process: CM2 Source Classification Code: 3-04-001-03 Process Description: CHIP MELTER #2 MELTS CLEAN ALUMINUM MACHINING CHIPS. Emission Source/Control: C0045 - Process Item 28.13: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: D- 00001 Process: ALB Source Classification Code: 3-03-001-99 Process Description: ALUMINUM BURNISHER Emission Source/Control: DFF42 - Control Control Type: CENTRIFUGAL Emission Source/Control: DF142 - Process Item 28.14: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: D- 00001 Process: CCT Source Classification Code: 3-03-001-99 Process Description: EMULSIFIED OIL AND WATER SYSTEM FOR THE CONTINUOUS CASTER. Emission Source/Control: DII42 - Process Item 28.15: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: D- 00001 Process: PRT Source Classification Code: 3-04-001-99 Process Description: FABRICATED ALUMINUM BARS PASS THROUGH AN ENCLOSED SPRAY CHAMBER WHERE A CLEAR PROTECTIVE COATING IS APPLIED TO THE BASE METAL. THE COATING IS TRANSPARENT AND USES THE UNDERCOAT ALUMINUM AS A REFLECTIVE BASE. EMISSIONS PASS THROUGH A MIST COLLECTOR AND VENT INSIDE THE BUILDING. Emission Source/Control: DF073 - Process Item 28.16: Air Po llution Control Permit Conditions Page 59 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: D- 00001 Process: SKD Source Classification Code: 3-04-001-07 Process Description: SKIM AND DROSS AREA USED FOR PASSIVE COOLING OF SKIM AND DROSS. Emission Source/Control: DI016 - Control Control Type: FABRIC FILTER Emission Source/Control: DI116 - Process Item 28.17: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: F- 00001 Process: FB1 Source Classification Code: 3-03-001-05 Process Description: FUGITIVES FROM THE BULL BLOCK. PROCESS APPLIES HIGH BOILING POINT (GREATER THAN 300F) SOLVENT TO SLIGHTLY HOT METAL TO ADHERE METAL TO BLOCK. VOC EMISSIONS ARE INLCUDED ON THE ANNUAL EMISSI ONS STATEMENT. Emission Source/Control: FFFB1 - Process Item 28.18: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: F- 00001 Process: FB2 Source Classification Code: 3-03-001-99 Process Description: FUGITIVES FROM THE INK JET PRINTER. METHYL ETHYL KETONE (MEK) USED AS A CARRIER SOLVENT. MEK EMISSIONS ARE INCLUDED ON THE ANNUAL EMISSIONS STATEMENT. Emission Source/Control: FFFB2 - Process Item 28.19: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: F- 00001 Process: FB3 Source Classification Code: 2-88-888-01 Process Description: FUGITIVES FROM WAX DIPPING AND AIR DRYING Air Po llution Control Permit Conditions Page 60 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 COILS. WAX IS MIXED WITH WATER AND HEATED,THUS DOES NOT HAVE A HIGH, VOC CONTENT. VOC EMISSIONS INCLUDED ON ANNUAL EMISSIONS STATEMENT. Emission Source/Control: FFFB3 - Process Item 28.20: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: F- 00001 Process: FC1 Source Classification Code: 2-88-888-01 Process Description: FUGITIVES FROM THE ROD OILER ASSOCIATED WITH THE CONTINUOUS CASTER. VOC EMISSIONS WILL BE INCLUDED ON THE ANNUAL EMISSI ONS STATEMENT. Emission Source/Control: FIFC1 - Process Item 28.21: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: F- 00001 Process: FC2 Source Classification Code: 2-88-888-01 Process Description: FUGITIVES FROM THE AUTOMATIC LATHE. VOC EMISSIONS WILL BE INCLUDED ON THE ANNUAL EMISSIONS STATEMENT. Emission Source/Control: FIFC2 - Process Item 28.22: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: F- 00001 Process: FC3 Source Classification Code: 3-03-001-99 Process Description: TWO (2) MOLD SHOP BAKE OVENS. SMALL OVEN IS USED TO VOLATILIZE OIL IMPREGNA TED IN GRAPHITE RINGS. EMISSIONS VENT INTO THE MILL AND ESTIMATED TO BE INSIGNIFICANT. Emission Source/Control: FIFC3 - Process Item 28.23: This permit authorizes the following regul ated processes for the cited Emission Unit:

Air Po llution Control Permit Conditions Page 61 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Emission Unit: M- 00001 Process: MHA Source Classification Code: 3-04-001-99 Process Description: MOLTEN ALUMINUM MELTING AND HOLDING FURNACES. CURRENTLY, THESE FURNACES ARE NOT PERMITTED TO USE SALT FLUXES. Emission Source/Control: M001A - Process20 Emission Source/Control: M001B - Process Emission Source/Control: M024C - Process Emission Source/Control: M024D - Process Emission Source/Control: M024F - Process Item 28.24: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: M- 00001 Process: MHS Source Classification Code: 3-04-001-99 Process Description: MOLTEN ALUMINUM MELTING AND HOLDING FURNACES WHICH ARE PERMITTED TO USE SALT FLUXES AT THE TIME OF TITLE V APPLICATION SUBMISSION. ALL FURNACES ARE REVERBERATORY, CENTER CHARG ED. NO GAS FLUXING IS DONE IN ANY FURNACE. Emission Source/Control: M001C - Process Emission Source/Control: M001D - Process Emission Source/Control: M0034 - Process Emission Source/Control: M0035 - Process Emission Source/Control: M003A - Process Emission Source/Control: M003C - Process Item 28.25: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: M- 00002 Process: FBA Source Classification Code: 3-04-001-04 Process Description: Air Po llution Control Permit Conditions Page 62 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 IN-LINE FILTERBOX FLUXING UNITS USE A MIXTURE OF ARGON AND CHLORINE GAS TO PURIFY MOULTEN ALUMINUM AS IT IS BEING CAST INTO INGOTS OR ROD. TYPICALLY THERE IS ONE FILTERBOX PER FURNACE, AND MULTIPLE FURNACES/FILTERBOXES SERVE AS A SINGLE CASTING COMPLEX. WITHIN A CASTING COMPLEX. THESE FILTERBOXES CAN BE EXHAUSTED TO GETHER OR INDIVIDUALLY, HOWEVER, ONLY ONE FILTERBOX IS FLUXING AT ANY TIME SINCE THERE IS ONLY ONE CASTING APPARATUS PER COMPLEX. THUS, ONLY ONE FILTERBOX EMISSION SOURCE AND POINT REPRESENTS ALL FILTERBOXES IN A CASTING COMPLEX. Emission Source/Control: M001E - Process Emission Source/Control: M0036 - Process Emission Source/Control: M003E - Process Emission Source/Control: M024E - Process Item 28.26: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: P- 00001 Process: PWS Source Classification Code: 4-01-003-35 Process Description: This process consists of all the cold cleaning parts washers. Emission Source/Control: PARTS - Process Item 28.27: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00001 Process: POT Source Classification Code: 3-03-001-01 Process Description: ELECTROLYTIC REDUCTION OF ALUMINA INTO ALUMINUM. THIS POTLINE IS CATEGORIZED AS A CENTER WORK PREBAKE-1 (CWPB-1) AS DESCRIBED IN THE DEFINITIONS SECTION OF EPA'S PRIMARY ALUMINUM MACT REGULATIONS. Emission Source/Control: SA398 - Control Control Type: SCRUBBER - DRY ALUMINA INJECTION Air Po llution Control Permit Conditions Page 63 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Source/Control: SS198 - Process Item 28.28: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00002 Process: BAK Source Classification Code: 3-03-001-05 Process Description: ANODE BAKING FURNACE AND ASSOCIATED ALUMINA INJECTION DRY SCRUBBER. Emission Source/Control: SS78S - Control Control Type: SCRUBBER - DRY ALUMINA INJECTION Emission Source/Control: SS078 - Process Item 28.29: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00003 Process: GMS Source Classification Code: 3-03-003-99 Process Description: PASTE PRODUCTION PLANT AND ASSOCIATED COKE INJECTION SCRUBBER. Emission Source/Control: SS100 - Control Control Type: SCRUBBER - DRY COKE INJECTION Emission Source/Control: SS099 - Process Item 28.30: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M01 Source Classification Code: 3-03-003-12 Process Description: BUILDING 332 DUST COLLECTION EQUIPMENT INCLUDES A STUB HOLE CLEANER WHICH USES AIR TO BLOW COKE DUST OUT OF STUB HOLES. PROCESS M01 ALSO INCLUDES TWO SMALL INDUCTION FURNACES USED FOR MELTING IRON, AND ANTHRACITE COAL HANDLING AND STORAGE. Emission Source/Control: SS015 - Control Control Type: FABRIC FILTER Emission Source/Control: SS016 - Control Air Po llution Control Permit Conditions Page 64 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Control Type: FABRIC FILTER Emission Source/Control: SS017 - Control Control Type: FABRIC FILTER Emission Source/Control: SS415 - Process Item 28.31: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M02 Source Classification Code: 3-09-005-00 Process Description: ELECTRIC WELDER USED TO WELD ALUMINUM, COPPER, AND STEEL TOGETHER. WELD IS PRODUCED UNDER HIGH CURRENT AND HYDRAULIC PRESSURE. Emission Source/Control: SS083 - Control Control Type: FABRIC FILTER Emission Source/Control: SS483 - Process Item 28.32: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M03 Source Classification Code: 3-03-003-12 Process Description: PACKED COKE DRILLED OUT OF A NODE STUB HOLES. Emission Source/Control: SS095 - Control Control Type: FABRIC FILTER Emission Source/Control: SS495 - Process Item 28.33: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M04 Source Classification Code: 3-03-001-04 Process Description: DRY SCRUBBER ALUMINA LOADING AND UNLOADING AREA. Emission Source/Control: SS090 - Control Control Type: FABRIC FILTER Emission Source/Control: SS490 - Process Item 28.34: Air Po llution Control Permit Conditions Page 65 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M05 Source Classification Code: 3-03-001-05 Process Description: ROUGH CLEANING OF SPENT ANODES. Emission Source/Control: S23AB - Control Control Type: FABRIC FILTER Emission Source/Control: 423AB - Process Item 28.35: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M06 Source Classification Code: 3-04-022-10 Process Description: BATH HANDLING, CRUSHING AND CRUCIBLE DIGGING OPERATIONS. Emission Source/Control: S23AA - Control Control Type: FABRIC FILTER Emission Source/Control: S23AC - Control Control Type: FABRIC FILTER Emission Source/Control: 423AA - Process Item 28.36: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M07 Source Classification Code: 3-03-001-04 Process Description: TRANSFER POINT IN BUILDING 441 FOR TWO ALUMINA BELT CONVEYORS. Emission Source/Control: SS041 - Control Control Type: FABRIC FILTER Emission Source/Control: SS441 - Process Item 28.37: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M08 Source Classification Code: 3-03-003-12 Process Description: BUTT CRUSHING. Air Po llution Control Permit Conditions Page 66 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Source/Control: SS038 - Control Control Type: FABRIC FILTER Emission Source/Control: SS438 - Process Item 28.38: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M09 Source Classification Code: 3-03-001-05 Process Description: ANODE BUTT STORAGE, STORAGE FILLING, AGGREGATE BLENDING, COKE CRUSHING, STORAGE DISCHARGE, BALL MILL CLASSIFYING, AND INTERMEDIATE CLASSIFYING. Emission Source/Control:

0 SS049 - Control Control Type: FABRIC FILTER Emission Source/Control: SS050 - Control Control Type: FABRIC FILTER Emission Source/Control: SS051 - Control Control Type: FABRIC FILTER Emission Source/Control: SS052 - Control Control Type: FABRIC FILTER Emission Source/Control: SS053 - Control Control Type: FABRIC FILTER Emission Source/Control: SS060 - Control Control Type: FABRIC FILTER Emission Source/Control: SS061 - Control Control Type: FABRIC FILTER Emission Source/Control: SS449 - Process Item 28.39: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M10 Source Classification Code: 3-03-001-04 Process Description: STORAGE TANK 440A AND 440B FLUIDIZER FOR ALUMINA Emission Source/Control: SS086 - Control Air Po llution Control Permit Conditions Page 67 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Control Type: FABRIC FILTER Emission Source/Control: SS486 - Process Item 28.40: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M11 Source Classification Code: 3-03-001-04 Process Description: TRACK HOPPER DUST COLLECTOR FOR ALUMINA UNLOADING AND ALUMINA AIRLIFT TOWER DUST COLLECTOR. Emission Source/Control: SS092 - Control Control Type: FABRIC FILTER Emission Source/Control: SS093 - Control Control Type: FABRIC FILTER Emission Source/Control: SS492 - Process Item 28.41: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M12 Source Classification Code: 3-03-001-04 Process Description: TRANSFER POINT 441C SERVES ST 441C AND THE TRANSFER OF ALUMINA TO ST441B. Emission Source/Control: SS043 - Control Control Type: FABRIC FILTER Emission Source/Control: SS443 - Process Item 28.42: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M13 Source Classification Code: 3-03-001-04 Process Description: ALUMINA TRANSFER POINT 446A FROM REACTORS TO STORAGE TANKS. Emission Source/Control: SS046 - Control Control Type: FABRIC FILTER

Air Po llution Control Permit Conditions Page 68 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Emission Source/Control: SS446 - Process Item 28.43: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M14 Source Classification Code: 3-03-001-04 Process Description: ALUMINA TRANSFER POINT 446B FROM REACTORS TO STORAGE TANKS. Emission Source/Control: SS047 - Control Control Type: FABRIC FILTER Emission Source/Control: SS447 - Process Item 28.44: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M15 Source Classification Code: 3-03-001-04 Process Description: ALUMINA TRANSFER POINT 446C FROM REACTORS TO STORAGE TANKS. Emission Source/Control: SS048 - Control Control Type: FABRIC FILTER Emission Source/Control: SS448 - Process Item 28.45: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00004 Process: M16 Source Classification Code: 3-03-003-12 Process Description: POT DIGGING AND SPENT POTLINING HANDLING OPERATIONS CONTROLLED BY A FABRIC FILTER TO LIMIT PARTICULATE EMISSIONS TO THE ENVIRONMENT. Emission Source/Control: SS102 - Control Control Type: FABRIC FILTER Emission Source/Control: SS402 - Process Item 28.46: This permit authorizes the following regul ated processes for the cited Emission Unit: Air Po llution Control Permit Conditions Page 69 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Unit: S- 00005 Process: PST Source Classification Code: 3-03-003-12 Process Description: 0 COAL TAR PITCH INCLUDES A SINGLE EMISS ION POINT (EP) SERVING EACH OF TWO COAL TAR PITCH STORAGE TANKS, AND FU GITIVES INCLUDING BUT NOT LIMITED TO THOSE ASSOCIATED WITH THE PITCH RECIRCULATING PUMPS LOCATED IN BUILDING 352F. Emission Source/Control: SS088 - Process Emission Source/Control: SS089 - Process Emission Source/Control: SSFP2 - Process Item 28.47: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00005 Process: PUN Source Classification Code: 3-03-003-12 Process Description: COAL TAR PITCH UNLOADING INCLUDES A SINGLE EMISSION POINT (EP) SERVING EACH OF TWO RAILCAR UNLOADING STATIONS, AND FUGITIVES INCLUDING BUT NOT LIMITED TO THOSE ASSOCIATED WITH THE PITCH UNLOADING PUMPS. SOME OF THESE FUGITIVES ARE EXHAUSTED THROUGH THE BUILDING VENTILATOR DESIGNATED AS EP S073A. Emission Source/Control: SS073 - Process Emission Source/Control: SS077 - Process Emission Source/Control: SSFP1 - Process Item 28.48: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00006 Process: FA1 Source Classification Code: 3-03-003-12 Process Description: TOTAL SUSPENDED SOLID (I.E. PARTICULATE) FUGUTIVES FROM COKE UNLOADING. Emission Source/Control: SSFA1 - Process Air Po llution Control Permit Conditions Page 70 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Item 28.49: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00006 Process: FA2 Source Classification Code: 3-03-003-12 Process Description: TOTAL SUSPENDED SOLID (I.E. PARTICULATE) FUGITIVES FROM COKE STORAGE AND HANDLING. Emission Source/Control: SSFA2 - Process Item 28.50: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00006 Process: FA3 Source Classification Code: 3-03-001-05 Process Description: TOTAL SUSPENDED SOLID (I.E. PARTICULATE) FUGITIVES FROM CLAMSHELL BUCKET OPERATIONS IN THE ANODE BAKING FURNACE ROOM. Emission Source/Control: SSFA3 - Process Item 28.51: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00006 Process: FAC Source Classification Code: 3-03-001-05 Process Description: WHEN SPENT ANODES ARE PLACED IN BUILDING 380 AND 376 TO COOL, THERE ARE FUGITIVE EMISSIONS FROM PASSIVE ANODE COOLING. SOME HYDROGEN FLUORIDE IS EMITTED AS A RESULT OF THE RESIDUAL BATH ON THE ANODES. EMISSIONS ARE INCLUDED ON THE ANNUAL EMISSI ONS STATEMENT. Emission Source/Control: SSFAC - Process Item 28.52: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: S- 00006 Process: FSM Source Classification Code: 3-03-003-99 Process Description: SEAM MIX OPERATIONS INCLUDE: LOW TEMPERATURE PITCH UNLOADING AND STORAGE, Air Po llution Control Permit Conditions Page 71 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 THE MIXING OF PITCH, ANTHRACITE COAL AND LIQUID METHYLNAPTHALENE, AND THE PLACING OF FINAL PRODUCT IN BAGS. FUGITIVE E MISSI ONS CONSIST OF POLYCYCLIC ORGANIC MATTER. Emission Source/Control: SSFSM - Process Item 28.53: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: W- 00001 Process: OWT Source Classification Code: 3-03-001-99 Process Description: TREATMENT OF MISCELLANEOUS OILY WASTEWATERS USING A PRECOATE VACUUM FILTER. VACUUM EXHAUST IS THE EMISS ION POINT. Emission Source/Control: W0068 - Process Item 28.54: This permit authorizes the following regul ated processes for the cited Emission Unit: Emission Unit: W- 00001 Process: WWT Source Classification Code: 3-03-001-99 Process Description: WASTEWATER TREATMENT CONSISTS OF CHEMICAL PRE-TREATMENT, AND BIOLOGICAL TREATMENT. 0 Emission Source/Control: W0069 - Control Control Type: SODIUM-ALKALI SCRUBBING Emission Source/Control: W0070 - Process Emission Source/Control: W0071 - Process Condition 29: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.3(a) Item 29.1: The Compliance Certification ac tivity will be performed for: Emission Unit: A- 00001 Emission Point: F078A Process: HT2 Emission Source: AF78A Item 29.2: Compliance Certification shall include the following monitoring: Air Po llution Control Permit Conditions Page 72 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: No owner or o perator of a combustion installation shall emit greater than 20 percent opacity except for one six minute period per hour, not to exceed 27 percent, based upon the six minute average in reference test method 9 in Appendix A of 40 CFR 60. Parameter Monitored: OPACITY Upper Permit Lim it: 20 percent Reference Test Method: EPA RM 9 Averaging Method: 6-MINUTE AVERAGE (METHOD 9) Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 30: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.3(a) Item 30.1: The Compliance Certification ac tivity will be performed for: Emission Unit: A- 00001 Emission Point: F078B Process: HT2 Emission Source: AF78B Item 30.2: Compliance Certification shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: No owner or o perator of a combustion installation shall emit greater than 20 percent opacity except for one six minute period per hour, not to exceed 27 percent, based upon the six minute average in reference test method 9 in Appendix A of 40 CFR 60. Parameter Monitored: OPACITY Upper Permit Lim it: 20 percent Reference Test Method: EPA RM 9 Averaging Method: 6-MINUTE AVERAGE (METHOD 9) Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 31: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007

Air Po llution Control Permit Conditions Page 73 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Applicable Federal Requirement: 6NYCRR 212.4(a) Item 31.1: The Compliance Certification ac tivity will be performed for: Emission Unit: A- 00002 Process: FAB Regulated Contaminant(s): CAS No: 007439-92-1 LEAD Item 31.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: As required by 6 NYCRR Part 212.4(a) lead has been i ssued an environmental rating of A. The emission rate potential of lead from this process source shall remain less than 1 pound per hour. Compliance te sting shall be conduct ed upon request from the Department. Upper Permit Limit: 1. 0 pounds per hour Reference Test Method: EPA RM 29 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 32: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.4(a) Item 32.1: The Compliance Certification ac tivity will be performed for: Emission Unit: A- 00002 Process: MRS Regulated Contaminant(s): CAS No: 000050-00-0 FORMALDEHYDE Item 32.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Air Po llution Control Permit Conditions Page 74 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Monitoring Description: As required by 6 NYCRR Part 212.4(a) formaldehyde has been issued an environmental rating of A. The emission rate potential of formaldehyde from the emission sour ces in this process shall remain less than 1 pound per hour. Comp liance tes ting shall be conducted upon request from the Department. Upper Permit Limit: 1. 0 pounds per hour Reference Test Method: EPA RM 18 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 33: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.4(a) Item 33.1: The Compliance Certification ac tivity will be performed for: Emission Unit: A- 00002 Process: MRS Regulated Contaminant(s): CAS No: 000067-56-1 METHYL ALCOHOL Item 33.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: As required by 6 NYCRR Part 212.4(a) methanol has been issued an environmental rating of B. The emission rate potential of methanol from the emission sources in this process shall remain less than 10 pounds per hour. Compliance testing shall be done upon request from the Department. Upper Permit Limit: 10 pounds per hour Reference Test Method: EPA RM 18 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Air Po llution Control Permit Conditions Page 75 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 34: Corrective Action Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.6(a) Item 34.1: This Condition applies to Emission Unit: B- 00001 Item 34.2: Any facility found in violation of the provisions of this Part shall not cause, permit, or allow the operation of the affected stationary combustion installation unless: (1) it is equipped with approved emission control equipment; (2) it is rehabilitated or upgraded in an approved manner; or (3) the fuel is changed to an accepta ble type. Condition 35: Corrective Action Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.6(b) Item 35.1: This Condition applies to Emission Unit: B- 00001 Item 35.2: The commissioner may seal such stationary combustion installation so as to prevent any operation if the conditions of paragraphs 6 NYCRR Part 227-1.6(a)(1)-(3) are not met within the time provided by the order of final determ ination issued in the case of the violation. Condition 36: Corrective Action Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.6(c) Item 36.1: This Condition applies to Emission Unit: B- 00001 Item 36.2: No person shall cause, permit, or allow the op eration of any affected stationary combustion installation sealed by the commissioner in accordance with 6 NY CRR Part 227- 1.6. Condition 37: Corrective Action Effective between the dates of 09/01/2002 and 09/01/2007

Air Po llution Control Permit Conditions Page 76 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Applicable Federal Requirement: 6NYCRR 227-1.6(d) Item 37.1: This Condition applies to Emission Unit: B- 00001 Item 37.2: No person except the commissioner or his representatives shall remove, tamper with or destroy any seal affixed to any stationary combustion installation in accordance with 6 NYCRR Part 227-1.6. Condition 38: General Provisions Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.7 Item 38.1: This Condition applies to Emission Unit: B- 00001 Item 38.2: (a) Emission data. Any person who owns or operates a stationary combustion installation described in 6 NYCRR Part 227-1 shall provide pertinent data concerning emissions when so requested by the commissioner. (b) Test methods. Sampling, compositing and an alysis of fuel samples shall be carried out in accordance with the most recent ASTM standard methods or eq uivalent methods acceptable to the commissioner. Condition 39: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-2.4(b)(1) Item 39.1: The Compliance Certification ac tivity will be performed for: Emission Unit: B- 00001 Regulated Contaminant(s): CAS No: 0NY210-00-0 OXIDES OF NITROGEN Item 39.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: In order to comply with the NOx RACT requirements of 6 NYCRR Part 227-2 each of the four boilers in this emission unit shall not exceed an emission rate of 0.30 pounds per million Btu per hour. Air Po llution Control Permit Conditions Page 77 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Parameter Monitored: OXIDES OF NITROGEN Upper Permit Limit: 0.30 pounds per million Btus Reference Test Method: EPA RM 7E Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE Condition 40: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 225-1.2(d) Item 40.1: The Compliance Certification ac tivity will be performed for: Emission Unit: B- 00001 Process: OIL Regulated Contaminant(s): CAS No: 007446-09-5 SULFUR DIOXIDE Item 40.2: Compliance Certification shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: Sulfur content of Number 6 fuel oil used in this process shall not exceed 1.5% by weight. Process Material: NUMBER 6 OIL Parameter Monitored: SULFUR CONTENT Upper Permit Limit: 1.5 percent by weight Monitoring Frequency: PER DELIVERY Averaging Method: MAXIMUM - NOT TO BE EXCEEDED AT ANY TIME (I NSTANTANEOUS/D ISCRETE ORGRAB) Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 41: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 225-1.7(c) Item 41.1: The Compliance Certification ac tivity will be performed for:

Air Po llution Control Permit Conditions Page 78 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Emission Unit: B- 00001 Process: OIL Item 41.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Part 225-1.7(c) requires that measu rements must be made daily of the rate of each fuel burned. The gross heat content and ash content of each fuel burned must be determined at least once each week. This information must be retained by the source owner for a period of five years. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 42: Records retention Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 225-1.7(d) Item 42.1: This Condition applies to Emission Unit: B- 00001 Process: OIL Item 42.2: Data collected pur suant to 6 NYCRR Part 225-1.7 must be tabulated and summarized in a form acceptable to the commissioner, and must be retained for at least th ree years. The source owner must furnish such records and summaries upon request of the commissioner. Condition 43: Sulfur in fuel exception reporting Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 225-1.7(e) Item 43.1: This Condition applies to Emission Unit: B- 00001 Process: OIL Item 43.2: Source owners subject to 6 NYCRR Part 225-1.7 must submit a written report of the fuel sulfur content excceding the applicable sulfur-in-fuel limitation, or of measured emissi ons exceeding the applicable equivalent emission rate, and the nature and cause of such ex cesses if known, for the calendar q uarter. Condition 44: Compliance Certification Air Po llution Control Permit Conditions Page 79 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 225-1.8(a) Item 44.1: The Compliance Certification ac tivity will be performed for: Emission Unit: B- 00001 Process: OIL Item 44.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: THE PERMITTEE SHALL RETAIN FUEL OIL SUPPLIER CERTIFICATIONS FOR EACH SHIP MENT OF OIL RECEIVED. SUCH CERTIFICATIONS SHALL CONTAIN, AS A MINIMUM: SUPPLIER NAME, DATE OF SHIPMENT, QUANTITY SHIPPED, OIL SULFUR CONTENT, AND THE METHOD USED TO DETERMINE THE SULFUR CONTENT. SUCH CERTIFICATIONS SHALL BE AVAILABLE FOR INSPECTION BY, OR SUBMITTAL TO, NYSDEC UPON REQUEST. Monitoring Frequency: PER DELIVERY Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 45: Sampling, compositing, and analysis of fuel samples Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 225-1.8(d) Item 45.1: This Condition applies to Emission Unit: B- 00001 Process: OIL Item 45.2: All sampling, compositing, and analysis of fuel samples, taken to determine compliance with 6 NYCRR Part 225-1, must be done in accordance with methods acceptable to the commissioner. Condition 46: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.4(b) Item 46.1: Air Po llution Control Permit Conditions Page 80 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 The Compliance Certification ac tivity will be performed for: Emission Unit: B- 00001 Process: OIL Item 46.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of a stationary combustion installation wh ich utilizes a continuous opacity monitoring system (COMS) shall include the following in their quarterly excess emission reports: 1) Magnitude, date, and time of each exceedence; 2) For each pe riod of excess emissi ons, sp ecific identification of the cause and corrective action taken; 3) Date, time, and duration of each period of COMS downtime, and the corrective action for each period of downtime; 4) Total time the COMS is required to record data during the reporting period; 5) The total number of exceedences and the duration of exceedences expressed as a percentage of the total time in which the COMS are required to record data; and 6) Such other requirements as the Department may deem necessary in order to enforce Article 19 of the Environmental Conservation Law (ECL). Reporting Requirements: QUARTERLY (CALENDAR) Reports due 60 days after the reporting period. The initial report is due 11/29/02. Subsequent reports are due every 3 calendar mont h(s). Condition 47: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.3(a) Item 47.1: The Compliance Certification ac tivity will be performed for: Air Po llution Control Permit Conditions Page 81 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Unit: B- 00001 Process: OIL Emission Source: B0001 Item 47.2: Compliance Certification shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: No owner or o perator of a combustion installation shall emit greater than 20 percent opacity except for one six minute period per hour, not to exceed 27 percent, based upon the six minute average utilizing a continuous opacity monitor (COM). Parameter Monitored: OPACITY Upper Permit Lim it: 20 percent Reference Test Method: EPA Meth 9 Monitoring Frequency: CONTINUOUS Averaging Method: 6 MINUTE AVERAGE Reporting Requirements: QUARTERLY (CALENDAR) Reports due 60 days after the reporting period. The initial report is due 11/29/02. Subsequent reports are due every 3 calendar mont h(s). Condition 48: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.3(a) Item 48.1: The Compliance Certification ac tivity will be performed for: Emission Unit: B- 00001 Process: OIL Emission Source: B0002 Item 48.2: Compliance Certification shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: No owner or o perator of a combustion installation shall emit greater than 20 percent opacity except for one six minute period per hour, not to exceed 27 percent, based upon the six minute average utilizing a continuous opacity monitor (COM). Air Po llution Control Permit Conditions Page 82 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Parameter Monitored: OPACITY Upper Permit Lim it: 20 percent Reference Test Method: EPA Meth 9 Monitoring Frequency: CONTINUOUS Averaging Method: 6 MINUTE AVERAGE Reporting Requirements: QUARTERLY (CALENDAR) Reports due 60 days after the reporting period. The initial report is due 11/29/02. Subsequent reports are due every 3 calendar mont h(s). Condition 49: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.3(a) Item 49.1: The Compliance Certification ac tivity will be performed for: Emission Unit: B- 00001 Process: OIL Emission Source: B0003 Item 49.2: Compliance Certification shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: 0 No owner or o perator of a combustion installation shall emit greater than 20 percent opacity except for one six minute period per hour, not to exceed 27 percent, based upon the six minute average utilizing a continuous opacity monitor (COM). Parameter Monitored: OPACITY Upper Permit Lim it: 20 percent Reference Test Method: EPA Meth 9 Monitoring Frequency: CONTINUOUS Averaging Method: 6 MINUTE AVERAGE Reporting Requirements: QUARTERLY (CALENDAR) Reports due 60 days after the reporting period. The initial report is due 11/29/02. Subsequent reports are due every 3 calendar mont h(s). Condition 50: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.3(a) Air Po llution Control Permit Conditions Page 83 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Item 50.1: The Compliance Certification ac tivity will be performed for: Emission Unit: B- 00001 Process: OIL Emission Source: B0004 Item 50.2: Compliance Certification shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: No owner or o perator of a combustion installation shall emit greater than 20 percent opacity except for one six minute period per hour, not to exceed 27 percent, based upon the six minute average utilizing a continuous opacity monitor (COM). Parameter Monitored: OPACITY Upper Permit Lim it: 20 percent Reference Test Method: EPA Meth 9 Monitoring Frequency: CONTINUOUS Averaging Method: 6 MINUTE AVERAGE Reporting Requirements: QUARTERLY (CALENDAR) Reports due 60 days after the reporting period. The initial report is due 11/29/02. Subsequent reports are due every 3 calendar mont h(s). Condition 51: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.3(a) Item 51.1: The Compliance Certification ac tivity will be performed for: Emission Unit: B- 00001 Emission Point: 00001 Process: GAS Item 51.2: Compliance Certification shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: No owner or o perator of a combustion installation shall emit greater than 20 percent opacity except for one six Air Po llution Control Permit Conditions Page 84 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 minute period per hour, not to exceed 27 percent, based upon the six minute average in reference test method 9 in Appendix A of 40 CFR 60. Parameter Monitored: OPACITY Upper Permit Lim it: 20 percent Reference Test Method: EPA RM 9 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: 6-MINUTE AVERAGE (METHOD 9) Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 52: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227.2(b)(1) Item 52.1: The Compliance Certification ac tivity will be performed for: Emission Unit: B- 00001 Emission Point: 00001 Process: OIL Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 52.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: Particulate emission limit for a stationary combustion installation firing oil. The owner or operator shall complete the following once per term of this permit: 1) submit, to the Department, an acceptable protocol for the testing of particulate emission limit cited in this condition, 2) perform a stack test, based upon the approved test protocol, to determine comp liance with the particulate emission limit cited in this condition, and 3) all records shall be maintained at the fac ility for a minimum of five years. Parameter Monitored: PARTICULATES Upper Permit Limit: 0.10 pounds per million Btus Air Po llution Control Permit Conditions Page 85 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Reference Test Method: Method 5 Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 53: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227-1.3(a) Item 53.1: The Compliance Certification ac tivity will be performed for: Emission Unit: B- 00001 Emission Point: 00002 Process: GAS Item 53.2: Compliance Certification shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: No owner or o perator of a combustion installation shall emit greater than 20 percent opacity except for one six minute period per hour, not to exceed 27 percent, based upon the six minute average in reference test method 9 in Appendix A of 40 CFR 60. Parameter Monitored: OPACITY Upper Permit Lim it: 20 percent Reference Test Method: EPA RM 9 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: 6-MINUTE AVERAGE (METHOD 9) Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 54: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 227.2(b)(1) Item 54.1: The Compliance Certification ac tivity will be performed for:

Air Po llution Control Permit Conditions Page 86 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Emission Unit: B- 00001 Emission Point: 00002 Process: OIL Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 54.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: Particulate emission limit for a stationary combustion installation firing oil. The owner or operator shall complete the following once per term of this permit: 1) submit, to the Department, an acceptable protocol for the testing of particulate emission limit cited in this condition, 2) perform a stack test, based upon the approved test protocol, to determine comp liance with the particulate emission limit cited in this condition, and 3) all records shall be maintained at the fac ility for a minimum of five years. Parameter Monitored: PARTICULATES Upper Permit Limit: 0.10 pounds per million Btus Reference Test Method: Method 5 Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 55: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 231-2.2(d)(3) Item 55.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00001 Regulated Contaminant(s): Air Po llution Control Permit Conditions Page 87 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 CAS No: 0NY998-00-0 VOC Item 55.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: The emission rate of volatile organic comp ounds (VOC) from this emission unit shall not exceed 9.1 pounds per hour. Upper Permit Limit: 9. 1 pounds per hour Reference Test Method: METHOD 25A Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE Condition 56: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 231-2.2(d)(3) Item 56.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00001 Regulated Contaminant(s): CAS No: 0NY210-00-0 OXIDES OF NITROGEN Item 56.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: The emission rate of nitrogen oxides (NOx) from this emission unit shall not exceed 9.1 pounds per hour. Upper Permit Limit: 9. 1 pounds per hour Reference Test Method: METHOD 7E Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE Condition 57: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Air Po llution Control Permit Conditions Page 88 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Applicable Federal Requirement: 40CFR 52.21(i)(1), Subpart A

### r Item 57.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00001 Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 57.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: The emission rate of particulate matter (PM) from this emission unit shall not exceed 5.6 pounds per hour. Upper Permit Limit: 5. 6 pounds per hour Reference Test Method: METHOD 5 Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE Condition 58: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.10(c)(4)(i) Item 58.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00001 Process: CD1 Emission Source: C029B Regulated Contaminant(s): CAS No: 0NY998-00-0 VOC Item 58.2: Compliance Certification shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: Owner shall determine co mpliance with the VOC RACT requirements of 6 NYCRR Part 212.10(c)(4)(i) by performing

Air Po llution Control Permit Conditions Page 89 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 a stack test on the exhaust gas emissions of emission control C029B and comparing that to the inlet VOC concentration as determined by the following method:

Inlet VOC = (%residual lubeon chips) x (tons chips processed during test) Overall removal efficiency = [(inlet VOC) - (exhaust gas VOC from test)/(inlet VOC)] x 100 Parameter Monitored: VOC Lower Permit Limit: 81 percent reduction by we ight Reference Test Method: EPA RM 18 or 25A Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Averaging Method: 1-HOUR AVERAGE Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE Condition 59: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.11(b)(1) Item 59.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00001 Process: CD1 Emission Source: C029B Regulated Contaminant(s): CAS No: 0NY998-00-0 VOC Item 59.2: Compliance Certification shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: Owners and/or operators of any source equipped with a thermal incinerator for emissions control equipment must install a conti nuous monitor and data recorder for exhaust gas temperature. The conti nuous monitor must be operated at all times when the associated process equipment is operating except during any quality assurance and routine maintenance activities. The Conti nuous Monitoring System (CMS) will be operated and ma intained according to a CMS Operation and Maintenance (CMS O&M) Plan that will be submitted to the Department for review and a pproval. The Air Po llution Control Permit Conditions Page 90 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 CMS O&M Plan will be updated as needed and any changes will be submitted to the Department for approval. In order to ensure Process CD1 maintains 81% destruction of VOC, the afterburner (emission control C 029B) must be operated with a minumum exhaust gas temperature of 1200 degrees Fahrenheit. Parameter Monitored: TEMPERATURE Lower Permit Limit: 1200 degr ees Fahrenheit Monitoring Frequency: CONTINUOUS Averaging Method: 2-HOUR BLOCK AVERAGE Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 60: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.4(a) Item 60.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00001 Emission Point: I0029 Process: CD1 Regulated Contaminant(s): CAS No: 000630-08-0 CARBON MONOXIDE Item 60.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING 

### Monitoring Description: Carbon Monoxide emissions from the fac ility were given an environmental rating of "C". Measured emissions at emission point I0029 (#1 Chip Dryer) were 13.3 p ounds per hour which requires 70% control or Best Available Control Technology (BACT). A BACT analysis shall be submitted within 120 days of the permit issue d ate to show compliance with 212.5(d).
Upper Permit Limit: 10. 0 pounds per hour Reference Test Method: EPA method 10

Air Po llution Control Permit Conditions Page 91 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Averaging Method: 1-HOUR AVERAGE Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 61: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.4(a) Item 61.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00001 Emission Point: I0029 Process: CD1 Regulated Contaminant(s): CAS No: 000111-42-2 ETHANOL, 2,2'-IMINOBISItem 61.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: As required by 6 NYCRR Part 212.4(a) diethanolamine has been issued an environmental rating of B. The emission rate potential of diethanolamine from each emission source in this process shall remain less than 10 pounds per hour. Emission testing shall be conducted upon request from the Department. Upper Permit Limit: 10. 0 pounds per hour Reference Test Method: EPA RM 18 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 62: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.10(c)(3) Item 62.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00001 Emission Point: I0030 Process: CM1 Emission Source: C0030 Air Po llution Control Permit Conditions Page 92 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
Regulated Contaminant(s): CAS No: 0NY210-00-0 OXIDES OF NITROGEN Item 62.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The NOx RACT compliance pl an submitted to NYSDEC in 1994 determined control of NOx was not technically or economically feasible at that time. The current equip ment configuration meets NOx RACT. Reference Test Method: EPA RM 7E Monitoring Frequency: SINGLE OCCURRENCE Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 63: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.10(f) Item 63.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00002 Regulated Contaminant(s): CAS No: 0NY210-00-0 OXIDES OF NITROGEN Item 63.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Operation of the chip dryer and melter (emission sources C0044 & C0045) with low NOx burners and staged air combustion is considered RACT for the purposes of 6 NYCRR Part 212.10(f). Reference Test Method: EPA RM 7E Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY

Air Po llution Control Permit Conditions Page 93 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Condition 64: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 231-2.2(d)(3) Item 64.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00002 Regulated Contaminant(s): CAS No: 0NY210-00-0 OXIDES OF NITROGEN Item 64.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: The emission rate of nitrogen oxides (NOx) from this emission unit shall not exceed 9.1 pounds per hour. Upper Permit Limit: 9. 1 pounds per hour Reference Test Method: METHOD 7E Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT f0 Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE Condition 65: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 231-2.2(d)(3) Item 65.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00002 Regulated Contaminant(s): CAS No: 0NY998-00-0 VOC Item 65.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: The emission rate of volatile organic comp ounds (VOC) from this emission unit shall not exceed 9.1 pounds per Air Po llution Control Permit Conditions Page 94 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 hour. Upper Permit Limit: 9. 1 pounds per hour Reference Test Method: METHOD 25A Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE Condition 66: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 52.21(i)(1), Subpart A Item 66.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00002 Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 66.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: The emission rate of particulate matter (PM) from this emission unit shall not exceed 3.4 pounds per hour. Upper Permit Limit: 3. 4 pounds per hour Reference Test Method: METHOD 5 Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE Condition 67: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.4(a) Item 67.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00002 Process: CD2

Air Po llution Control Permit Conditions Page 95 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Regulated Contaminant(s): CAS No: 000630-08-0 CARBON MONOXIDE Item 67.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: As required by 6 NYCRR Part 212.4(a) carbon monoxide (CO) has been issued an environmental rating of C. The emission rate potential of carbon monoxide from each emission source in this process shall remain less than 10 p ounds per hour. Compliance tes ting shall be conducted upon request from the Department. Upper Permit Limit: 10. 0 pounds per hour Reference Test Method: EPA RM 10 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 68: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.4(a) Item 68.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00002 Process: CD2 Regulated Contaminant(s): CAS No: 000111-42-2 ETHANOL, 2,2'-IMINOBISItem 68.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: As required by 6 NYCRR Part 212.4(a) diethanolamine has been issued an environmental rating of B. The emission rate potential of diethanolamine from each emission source in this process shall remain less than 10 pounds per hour. Emission testing shall be conducted upon request from the Department. Air Po llution Control Permit Conditions Page 96 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
Upper Permit Limit: 10. 0 pounds per hour Reference Test Method: EPA RM 18 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 69: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.10(c)(4)(i) Item 69.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00002 Process: CD2 Emission Source: C044B Regulated Contaminant(s): CAS No: 0NY998-00-0 VOC Item 69.2: Compliance Certification shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: Owner shall determine co mpliance with the VOC RACT requirements of 6 NYCRR Part 212.10(c)(4)(i) by performing a stack test on the exhaust gas emissions of emission control C044B and comparing that to the inlet VOC concentration as determined by the following method:

Inlet VOC = (%residual lubeon chips) x (tons chips processed during test) Overall removal efficiency = [(inlet VOC) - (exhaust gas VOC from test)/(inlet VOC)] x 100 Parameter Monitored: VOC Lower Permit Lim it: 81 percent Reference Test Method: EPA RM 18 or 25A Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Averaging Method: 1-HOUR AVERAGE Reporting Requirements: ONCE / BATCH OR MONITORING OCCURRENCE Air Po llution Control Permit Conditions Page 97 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Condition 70: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.11(b)(1) Item 70.1: The Compliance Certification ac tivity will be performed for: Emission Unit: C- 00002 Process: CD2 Emission Source: C044B Regulated Contaminant(s): CAS No: 0NY998-00-0 VOC Item 70.2: Compliance Certification shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: Owners and/or operators of any source equipped with a thermal incinerator for emissions control equipment must install a conti nuous monitor and data recorder for exhaust gas temperature. The conti nuous monitor must be operated at all times when the associated process equipment is operating except during any quality assurance and routine maintenance activities. The Conti nuous Monitoring System (CMS) will be operated and ma intained according to a CMS Operation and Maintenance (CMS O&M) Plan that will be submitted to the Department for review and approval within 90 days of issuance of the pe rmit. The CMS O&M Plan will be updated as needed and an y changes will be submitted to the Department for approval. In order to ensure Process CD2 maintains an acceptable level of VOC reduction, the thermal incinerator (emission control C044B) must be operated with a minimum exhaust gas temperature of 1400 degrees Fahrenheit. Parameter Monitored: TEMPERATURE Lower Permit Limit: 1400 degr ees Fahrenheit Monitoring Frequency: CONTINUOUS Averaging Method: 2-HOUR BLOCK AVERAGE Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Air Po llution Control Permit Conditions Page 98 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Condition 71: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 228.2 Item 71.1: The Compliance Certification ac tivity will be performed for: Emission Unit: D- 00001 Process: PRT Regulated Contaminant(s): CAS No: 0NY998-00-0 VOC Item 71.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: For all surf ace coatings subjectto 6NY CRR Part 228, the VOC content (as applied, minus water and exempt VOC), must be less than or equal to the limit specified in Table 1 or Table 2 for the respective surface that is coated. The VOC content of a coating, as applied, is calculated as follows: (VOC)a= (Dc)a { [(Wv)a - (Ww)a- (We)a)] / [ 1- [(Vw)a + (Ve)a] ] } Where: (VOC)a = VOC content of "as applied" coating, expressed as a mass of VOC in pounds, per gallon of coating, in gallons, minus water and exempt VOC (Dc)a= Coating density as applied, in pounds per gallon (Wv)a= The weight frac tion of total vo latiles in the coating, as applied (Ww)a= The weight fraction of water in the coating, as applied (Vw)a= The volume fraction of water in the coating, as applied (We)a= The weight fraction of exempt VOCs in the coating, as applied (Ve)a= The volume fraction of exempt VOCs in the coating, as applied

Air Po llution Control Permit Conditions Page 99 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Reference Test Method: Method 24 (40CFR60) Averaging Method: MAXIMUM - NOT TO BE EXCEEDED AT ANY TIME (I NSTANTANEOUS/D ISCRETE ORGRAB) Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 72: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 228.5(a) Item 72.1: The Compliance Certification ac tivity will be performed for: Emission Unit: D- 00001 Process: PRT Item 72.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Certification from the coating supplier/manufact urer which verifies the parameters used to determine the actual VOC content of the as applied coating, for each coating used at the facility, must be m aintained and, upon request, be provided to the departments representative. In addition, purchase, usage and/or production records of the coating material, including solvents, must be maintained and, upon request, be submitted to the department. Records must be maintained at the facility for a period of five years. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 73: method 24 40 CFR 60 Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 228.5(b) Item 73.1: This Condition applies to Emission Unit: D- 00001 Process: PRT Item 73.2: Acceptable analytical met hods for determining the vo latile content, wate r content, density, volume of

Air Po llution Control Permit Conditions Page 100 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 solids and weight of solids of surface coatings are presented in appendix A, met hod 24, of 40 CFR 60. Condition 74: samples Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 228.5(d) Item 74.1: This Condition applies to Emission Unit: D- 00001 Process: PRT Item 74.2: Representatives of the department shall be permitted, during reasonable business hours, to obtain coating samples for the purpos e of determining compliance. Condition 75: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 228.7 Item 75.1: The Compliance Certification ac tivity will be performed for: Emission Unit: D- 00001 Process: PRT Regulated Contaminant(s): CAS No: 0NY998-00-0 VOC Item 75.2: Compliance Certification shall include the following monitoring: Monitoring Type: WORK PRACTICE INVOLVING SPECIFIC OPERATIONS Monitoring Description: Clear coats used for the surface coating of miscellaneous metal parts and products may contain a maximum of 4.3 pounds of volatile organic comp ounds per gallon of coating (minus water and excluded VOC) as applied. Work Practice Type: PARAMETER OF PROCESS MATERIAL Process Material: CLEAR COATINGS - MISCELLANEOUS METAL PARTS Parameter Monitored: VOC CONTENT Upper Permit Limit: 4.3 pounds per gallon Reference Test Method: Method 24 (40CFR60) Monitoring Frequency: SINGLE OCCURRENCE Averaging Method: MAXIMUM - NOT TO BE EXCEEDED AT ANY TIME (I NSTANTANEOUS/D ISCRETE ORGRAB) Air Po llution Control Permit Conditions Page 101 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 76: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 228.10 Item 76.1: The Compliance Certification ac tivity will be performed for: Emission Unit: D- 00001 Process: PRT Regulated Contaminant(s): CAS No: 0NY998-00-0 VOC Item 76.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: No owner or operator of a fac ility su bject to 6NYCRR Part 228 shall: (a) use open containers to store or dispose of cloth or paper impregnated with VOC and/or solvents that are used for surface preparation, cleanup, or coating removal; (b) store in open containers spent or fresh VOC and/or solvents to be used for surface preparation, cleanup, or coating removal; (c) use VOC and/or solvents to cleanup sp ray equipment unless equipment is used to collect the cleaning compounds and to minimize their evaporation to the atmosphere; (d) use open containers to store or dispe nse surface coatings and/or inks unless production, sampling, maintenance , or inspection procedures require operational access. This provision does not apply to the actual device or equipment designed for the purpose of applying a coating material to a substrate; or (e) use open containers to store or dispose of spent surface coatings, spent VOCs and/or solvents.

Air Po llution Control Permit Conditions Page 102 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 The surface coating operations shall be in spected daily to determine if there are any open containers present. Open containers, if f ound, shall be covered. Monitoring Frequency: DAILY Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 77: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 228.4 Item 77.1: The Compliance Certification ac tivity will be performed for: Emission Unit: D- 00001 Process: PRT Emission Source: DF073 Item 77.2: Compliance Certification shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: No person shall cause or allow emissions to the outdoor atmosphere having an average opacity of 20 percent or greater for any consecutive six-minute period from any emission source subject to 6NYCRR Part 228. The Department reserves the right to perform or require the performance of a Method 9 opacity evaluation Parameter Monitored: OPACITY Upper Permit Lim it: 20 percent Reference Test Method: EPA RM 5 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: 6-MINUTE AVERAGE (METHOD 9) Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 78: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.5(d) Item 78.1: The Compliance Certification ac tivity will be performed for:

Air Po llution Control Permit Conditions Page 103 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Emission Unit: M- 00001 Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 78.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The particulate matter (PM) emissions from this emission unit, are subject to t he Federal National Emission Standards for Hazardous Air Pollutants in 40 CFR part 63 Subpart RRR, which satisfy the requirements of Part 212.5(d) for PM emissions as l ong as the source owner continues to demonstrate that the emission unit is in compliance with the respec tive Federal requirements contained in this permit. Compliance testing shall be conducted upon request from the department. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 79: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1506(d) , Subpart RRR Item 79.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Item 79.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of each affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) of feed/charge must: (1) Except as provided in paragraph (3) of this condition, install and operate a device th at measures and records or otherwise determine the weight of feed/charge (or throughput) for each operating cycle or time period used in the emissions test; and Air Po llution Control Permit Conditions Page 104 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
(2) Operate each weight measurement system or other weight determination procedure in accordance with the manufacturer's recommendations. (3) The owner or operator may chose to measure and record aluminum production weight from an affected source or emission unit rather than feed/charge weight to an affected source or emission unit, provided that: (i) The aluminum production weight, rather than feed/charge weight is measured and recorded for all emission units within a SAPU; and (ii) All calculations to demonstrate compliance with the emission limits for SAPUs are based on aluminum production weight rather than feed/charge weight. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 80: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1506(p) , Subpart RRR Item 80.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Item 80.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: When a process parameter or add-on air pollution control device operating parameter deviates from the value or range established during the emissions test, the owner or operator must initiate co rrective action. Correc tive action must restore operation of the affected source or emission unit (including the process or control device) to its normal or usual mode of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. Corrective actions taken must include follow- up actions necessary to return the process or control device parameter level(s) to the Air Po llution Control Permit Conditions Page 105 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 value or range of values established during the emiss ions test and steps to prevent the likely recurrence of the cause of a deviation. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 81: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1510(e) , Subpart RRR Item 81.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Item 81.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of an affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) or ug/Mg (gr/ton) of feed/charge must install, calibrate, operate, and maintain a device to measure and record the total weight of feed/charge to, or the aluminum production from, the affected s ource or emission unit over the same operating cycle or time period used in the initial emissions test. Feed/charge or aluminum production within SAPUs must be measured and recorded on an emission unit-by-emission unit basis. As an alternative to a measurement device, the owner or operator may use a procedure accepta ble to the applicable permitting authority to determine the total weight of feed/charge or aluminum production to th e affected s ource or emission unit. (1) The accuracy of the weight measurement de vice or procedure must be ±5 percent of the weight being measured. The owner or operator may apply to the permitting agency for approval to use a device of alternative accur acy if the required accuracy cannot be achieved as a result of equipment layout or charging practices. A device of alternative accuracy will not be approved unless the owner or operator provides assurance through data and information that the aff ected source will meet the Air Po llution Control Permit Conditions Page 106 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 relevant emission standard. (2) The owner or operator must verify the cali bration of the weight measurement device in accordance with the schedule specified by the manufacturer, or if no calibration schedule is specified, at least once every 6 months. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 82: Calculation of Secondary Aluminum Processing Unit PM emissions Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1510(t), Subpart RRR Item 82.1: This Condition applies to Emission Unit: M- 00001 Item 82.2: Except as provided in paragraph 40 CFR Part 63.1510(u), the owner or operator must calculate and record the 3-day, 24-hour rolling average emi ssions of PM for each sec ondary aluminum processing unit on a daily basis. To calculate the 3-day, 24-hour rolling average, the owner or o perator must: (1) Calculate and record the total weight of material charged to each emission unit in the secondary aluminum processing unit for each 24-hour day of operation using the feed/charge weight inform ation required in paragraph (e) of this section. If the owner or operator c hooses to comply on the basis of weight of aluminum produced by the emission unit, rath er than weight of material charged to the emission unit, all performance test emissions results and all calculations must be conduct ed on the alum inum production weight basis. (2) Multiply the total feed/charge weight to the emission unit, or the weight of aluminum p roduced by the emission unit, for each emission unit for the 24-hour period by the emission rate (in l b/ton of feed/charge) for that emission unit (as determined duri ng the performance test) to provide emissions for each emission unit for the 24-hour period, in pounds. (3) Divide the total emissions for each SAPU for the 24-hour period by the totalmaterial ch arged to the SAPU, or the weight of aluminum produced by the SAPU over the 24-hour period to provide the daily emission rate for the SAPU. (4) Compute the 24-hour daily emission rate using the equation below:

Air Po llution Control Permit Conditions Page 107 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003



### E T ER

T day i i i n

i i n 

### = ×

=

= 

# ∑ ∑ ( ) 1

1
Where,
E day = The daily PM emission rate for the secondary aluminum processing unit for the 24-hour pe riod; T i = The total amount of feed, or aluminum produced, for emission unit i for the 24- hour pe riod (tons); ER i = The measured emission rate for emission unit i as determined in the performance test (lb/ton or μg/Mg of feed/charge); and n = The number of emission units in t he secondary aluminum processing unit. (5) Calculate and record the 3-day, 24-hour ro lling average of PM each day by summing the daily emission rates for each pollutant over the 3 most recent consecutive days and dividing by 3. Condition 83: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1511(a) , Subpart RRR Item 83.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Item 83.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Prior to conducting an emissions test required by this permit, the owner or operator must prepare and submit a site-specific test plan meeting the requirements in 6 NYCRR Part 202-1.2 and 202-1.3. Such plan shall be submitted to the Department within 90 days of issuance of this permit. Testing of the subject source must occur within 90 days of Department approval of the site-specific test plan. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION

Air Po llution Control Permit Conditions Page 108 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Condition 84: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1511(b) , Subpart RRR Item 84.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Item 84.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Following approval of the site -specific test plan, the owner or operator must demonstrate initial compliance with each applicable emission, equipment, work practice, or operational standard for each affected source and emission unit, and report the res ults to the Department within 90 days of achieving initial co mpliance. The owner or operator must conduct each emissions test according to the requirements of the general provisions in 40 CFR 63 subpart A and subpart RRR. (1) The owner or operator must conduct each test while the affected sour ce or emission unit is operating at the highest production level with charge materials representative of the range of materials processed by the unit and, if applicable, at the highest reactive flux rate. (2) Each emissions test for a conti nuous process must consist of 3 separate runs; pollutant sampling for each run must be conduct ed for the time period specified in the applicable method or, in the absence of a specific time period in the test method, for a minimum of 3 hours. (3) Each emissions test for a batch process must consist of three separate runs; pollutant sampling for each run must be conducted over the entire process operating cycle. (4) Where multiple affected sources or emission units are exhausted through a common stack, pollutant sampling for each run must be conducted over a period of time during which all affected sources or emission units complete at Air Po llution Control Permit Conditions Page 109 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 least 1 entire process operating cycle or for 24 hours, whichever is shorter. (5) Initial compliance with an applicable emission limit or standard is demonstrated if the average of three runs conducted during the initial emissions test is less than or equal to th e applicable emiss ion limit or standard. Reference Test Method: EPA RM 5 Monitoring Frequency: SINGLE OCCURRENCE Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 85: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1511(c) , Subpart RRR Item 85.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Item 85.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator must use the following methods in appendix A to 40 CFR part 60 to determine compliance with the applicable emission limits or standards: (1) Method 1 for sample and velocity traverses. (2) Method 2 for velocity and volumetric flow rate. (3) Method 3 for gas analysis. (4) Method 4 for moisture content of the stack gas. (5) Method 5 for the concentration of PM. (6) Method 9 for visible emission observations. Monitoring Frequency: AS REQUIRED - SEE MONITORING Air Po llution Control Permit Conditions Page 110 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 86: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1511(e) , Subpart RRR Item 86.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Item 86.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of new or existing emission units located at secondary aluminum production facilities that are major sources must conduct an emissions test every 5 years following the initial emissions test. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 87: Testing of Representative Emission Units Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1511(f) , Subpart RRR Item 87.1: This Condition applies to Emission Unit: M- 00001 Item 87.2: With the approval of the permitting authority, a sing le representative or similar group 1 furn ace or in-line fluxer which is not controlled by an add-on control device may be tested to determine the emission rate of all like affected sources at a facility provided that: (1) The tested emission unit must use identical feed/charge and flux materials in the same proportions as the emission units that it represents; (2) The tested emission unit is subject to the same work practices and the emissi on units that it represents; (3) The tested emission unit is of the same design as the emission units that it repres ents;

Air Po llution Control Permit Conditions Page 111 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 (4) The tested emission unit is tested under the highest load or capac ity reasonably expec ted to occur for any of the emission units that it represents; (5) At least one of each different style of emission unit at the facility is tested; and (6) All add-on control devices are tested. Condition 88: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1511(g) , Subpart RRR Item 88.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Item 88.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Establishment of monitoring and operating parameter values. The owner or operator of new or existing emission units must establish a minimum or maximum operating parameter value, or an operating parameter ra nge for each parameter to be monitored, as required by this permit, that ensures compliance with the applicable emission limit or standard. To establish the minimum or maximum value or range, the owner or operator must use the appropriate procedures in this section and submit the information required by 40 CFR Part 63.1515(b)(4), to the Department . The owner or operator may use existing data in addition to the results of emissions tests to establish operating parameter values for compliance monitoring provided each of the following conditions are met to the satisfaction of the applicable permitting authority: (1) The complete emission test report(s) used as the basis of the parameter(s) is submitted. (2) The same test methods and procedures as required by this subpart were used in the test. (3) The owner or operator certifies that no design or work practice changes have been made to the source, process, or emission control equipment since the time of the report. Air Po llution Control Permit Conditions Page 112 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
(4) All process and control equipment operating parameters required to be monitored were monitored as required in this subpart and documented in the test report. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 89: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1512(j), Subpart RRR Item 89.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 89.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator must conduct emission tests as described below. The results of the emission tests are used to establish emission rates in lb/ton of feed/charge for PM from each emission unit. These emission rates are used for compliance monito ring in the calculation of the 3-day, 24-hour rolli ng average emission rates using the equation in 40 CFR Part 63.1510(t). An emissions test is required for: (1) Each group 1 furnace tha t processes scrap other than clean charge to measure emissions of PM. (2) Each in-line fluxer to measure emissions of PM. Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 90: Performance Test/Compliance Demonstration Requirements and Procedures - Feed/Charge Weight Measurement. Effective between the dates of 09/01/2002 and 09/01/2007 Air Po llution Control Permit Conditions Page 113 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
Applicable Federal Requirement: 40CFR 63.1512(k) , Subpart RRR Item 90.1: This Condition applies to Emission Unit: M- 00001 Item 90.2: Feed/charge weight measurement. During the emission tes t(s) conducted to determine compliance with emission limits in a kg/Mg (lb/ton) format, the owner or operator of an affected source or emission unit, subject to an emission limit in a kg/Mg (lb/ton) of feed/charge format, must measure (or otherwise determine) and record the total weight of feed/charge to the affect ed source or emission unit for each of the three test runs and calcu late and record th e total weight. An owner or operator that chooses to demonstrate compliance on the b asis of the aluminum pr oduction weight must measure the weight of aluminum produced by the emission unit or affected source instead of the feed/charge wei ght. Condition 91: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1513(b) , Subpart RRR Item 91.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Item 91.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Use the Equation below to determine the emission rate of PM from the emission unit:

C x Q x K1 E = --------------

P

Where, E = Emission rate of PM, kg/Mg (lb/ton) of feed; C = Concentration of PM, g/dscm (gr/dscf); Air Po llution Control Permit Conditions Page 114 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Q = Volumetric flowrate of exhaust gases, dscm/hr (dscf/hr); K1 = Conversion factor, 1 kg/1, 000 g (1 lb/7,000 gr); and P = Production rate, Mg/hr (ton/hr). Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 92: Equations for Determining Compliance - Secondary Aluminum Processing Unit Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1513(e) , Subpart RRR Item 92.1: This Condition applies to Emission Unit: M- 00001 Item 92.2: Use the procedure below to determine comp liance with emission limits for a sec ondary aluminum processing unit. (1) Use the equation below to compute t he mass-weighted PM emissions for a secondary aluminum processing unit. Compliance is achi eved if the mass-weighted emissions fo r the secondary aluminum processing unit E CPM is less than or equal to the emission limit for the sec ondary alum inum processing unit L CPM calculated using Equation 1 in 40 CFR Part 63.1505(k).



### E E T

T C ti ti i n

ti i n P M P M



### = ×

=

= 

# ∑ ∑ ( ) ( ) 1

1 Where,
E CPM = The mass-weighted PM emissions for the secondary aluminum processing unit; E tiPM= Measured PM emissions for individual emission unit i; T ti = The average feed rate fo r individual emission unit i during the operating cycle or performance test period; and n=The number of emission units in t he secondary aluminum processing unit. Condition 93: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007

Air Po llution Control Permit Conditions Page 115 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Applicable Federal Requirement: 40CFR 63.1517(b)(7 ), Subpart RRR Item 93.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Item 93.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: For each emission unit subject to an emission standard in kg/Mg (lb/ton) of feed/charge, records of feed/charge (or throughput) weights for each operating cycle or time period used in the emissions test. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 94: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1517(b)( 17), Subpart RRR Item 94.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Item 94.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: For each secondary aluminum processing unit, records of total charge weight, or if the owner or operator chooses to comply on the basis of aluminum production, total aluminum produced for each 24-hour period and calculations of 3-day, 24- hour rolli ng average emissions. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Air Po llution Control Permit Conditions Page 116 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Condition 95: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.10(c)(3) Item 95.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Emission Point: I003C Process: MHS Emission Source: M003C Regulated Contaminant(s): CAS No: 0NY210-00-0 OXIDES OF NITROGEN Item 95.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Operation of the of th e #15 me lting and holding furn ace with low NOx burners is consid ered RACT for the purposes of 6 NYCRR Part 212.10(c)(3). Reference Test Method: EPA RM 7E Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 96: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.10(c)(3) Item 96.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00001 Emission Point: I024F Process: MHA Emission Source: M024F Regulated Contaminant(s): CAS No: 0NY210-00-0 OXIDES OF NITROGEN

Air Po llution Control Permit Conditions Page 117 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Item 96.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Operation of the of th e #32 me lting and holding furn ace with low NOx burners is consid ered RACT for the purposes of 6 NYCRR Part 212.10(c)(3). Reference Test Method: EPA RM 7E Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 97: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.5(d) Item 97.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00002 Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 97.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The particulate matter (PM) emissions from this emission unit, are subject to t he Federal National Emission Standards for Hazardous Air Pollutants in 40 CFR part 63 Subpart RRR, which satisfy the requirements of Part 212.5(d) for PM emissions as l ong as the source owner continues to demonstrate that the emission unit is in compliance with the respec tive Federal requirements contained in this permit. Compliance testing shall be conducted upon request from the Department. Monitoring Frequency: AS REQUIRED - SEE MONITORING Air Po llution Control Permit Conditions Page 118 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 98: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1506(d) , Subpart RRR Item 98.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00002 Item 98.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of each affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) of feed/charge must: (1) Except as provided in paragraph (3) of this condition, install and operate a device th at measures and records or otherwise determine the weight of feed/charge (or throughput) for each operating cycle or time period used in the emissions test; and (2) Operate each weight measurement system or other weight determination procedure in accordance with the manufacturer's recommendation. (3) The owner or operator may chose to measure and record aluminum production weight from an affected source or emission unit rather than feed/charge weight to an affected source or emission unit, provided that: (i) The aluminum production weight, rather than feed/charge weight is measured and recorded for all emission units within a SAPU; and (ii) All calculations to demonstrate compliance with the emission limits for SAPUs are based on aluminum production weight rather than feed/charge weight. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Air Po llution Control Permit Conditions Page 119 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Condition 99: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1506(p) , Subpart RRR Item 99.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00002 Item 99.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: When a process parameter or add-on air pollution control

0 device operating parameter deviates from the value or range established during the emissions test, the owner or operator must initiate co rrective action. Correc tive action must restore operation of the affected source or emission unit (including the process or control device) to its normal or usual mode of operation as expeditiously as practicable in accordance with good air pollution control practices for minimizing emissions. Corrective actions taken must include follow- up actions necessary to return the process or control device parameter level(s) to the value or range of values established during the emiss ions test and steps to prevent the likely recurrence of the cause of a deviation. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 100: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1510(e) , Subpart RRR Item 100.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00002 Item 100.2: Compliance Certification shall include the following monitoring:

Air Po llution Control Permit Conditions Page 120 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of an affected source or emission unit subject to an emission limit in kg/Mg (lb/ton) or ug/Mg (gr/ton) of feed/charge must install, calibrate, operate, and maintain a device to measure and record the total weight of feed/charge to, or the aluminum production from, the affected s ource or emission unit over the same operating cycle or time period used in the initial emissions test. Feed/charge or aluminum production within SAPUs must be measured and recorded on an emission unit-by-emission unit basis. As an alternative to a measurement device, the owner or operator may use a procedure accepta ble to the applicable permitting authority to determine the total weight of feed/charge or aluminum production to th e affected s ource or emission unit. (1) The accuracy of the weight measurement de vice or procedure must be ±5 percent of the weight being measured. The owner or operator may apply to the permitting agency for approval to use a device of alternative accur acy if the required accuracy cannot be achieved as a result of equipment layout or charging practices. A device of alternative accuracy will not be approved unless the owner or operator provides assurance through data and information that the aff ected source will meet the relevant emission standard. (2) The owner or operator must verify the cali bration of the weight measurement device in accordance with the schedule specified by the manufacturer, or if no calibration schedule is specified, at least once every 6 months. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 101: Calculation of Secondary Aluminum Processing Unit PM emissions Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1510(t), Subpart RRR Item 101.1: This Condition applies to Emission Unit: M- 00002

Air Po llution Control Permit Conditions Page 121 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Item 101.2: Except as provided in paragraph 40 CFR Part 63.1510(u), the owner or operator must calculate and record the 3-day, 24-hour rolling average emi ssions of PM for each sec ondary aluminum processing unit on a daily basis. To calculate the 3-day, 24-hour rolling average, the owner or o perator must: (1) Calculate and record the total weight of material charged to each emission unit in the secondary aluminum processing unit for each 24-hour day of operation using the feed/charge weight inform ation required in paragraph (e) of this section. If the owner or operator c hooses to comply on the basis of weight of aluminum produced by the emission unit, rath er than weight of material charged to the emission unit, all performance test emissions results and all calculations must be conduct ed on the alum inum production weight basis. (2) Multiply the total feed/charge weight to the emission unit, or the weight of aluminum p roduced by the emission unit, for each emission unit for the 24-hour period by the emission rate (in l b/ton of feed/charge) for that emission unit (as determined duri ng the performance test) to provide emissions for each emission unit for the 24-hour period, in pounds. (3) Divide the total emissions for each SAPU for the 24-hour period by the totalmaterial ch arged to the SAPU, or the weight of aluminum produced by the SAPU over the 24-hour period to provide the daily emission rate for the SAPU. (4) Compute the 24-hour daily emission rate using the equation below:



### E T ER

T day i i i n

i i n 

### = ×

=

= 

# ∑ ∑ ( ) 1

1
Where,
E day = The daily PM emission rate for the secondary aluminum processing unit for the 24-hour pe riod; T i = The total amount of feed, or aluminum produced, for emission unit i for the 24- hour pe riod (tons); ER i = The measured emission rate for emission unit i as determined in the performance test (lb/ton or μg/Mg of feed/charge); and n = The number of emission units in t he secondary aluminum processing unit. (5) Calculate and record the 3-day, 24-hour ro lling average of PM each day by summing the daily emission rates for each pollutant over the 3 most recent consecutive days and dividing by 3. Condition 102: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1511(a) , Subpart RRR

Air Po llution Control Permit Conditions Page 122 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Item 102.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00002 Item 102.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Prior to conducting an emissions test required by this permit, the owner or operator must prepare and submit a site-specific test plan meeting the requirements in 6 NYCRR Part 202-1.2 and 202-1.3. Such plan shall be submitted to the Department within 90 days of issuance of this permit. Testing of the subject source must occur within 90 days of Department approval of the site-specific test plan. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 103: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1511(b) , Subpart RRR Item 103.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00002 Item 103.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Following approval of the site -specific test plan, the owner or operator must demonstrate initial compliance with each applicable emission, equipment, work practice, or operational standard for each affected source and emission unit, and report the res ults to the Department within 90 days of achieving initial co mpliance. The owner or operator must conduct each emissions test according to the requirements of the general provisions in subpart A of this part and this subpart.

Air Po llution Control Permit Conditions Page 123 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 (1) The owner or operator must conduct each test while the affected sour ce or emission unit is operating at the highest production level with charge materials representative of the range of materials processed by the unit and, if applicable, at the highest reactive fluxing rate. (2) Each emissions test for a conti nuous process must consist of 3 separate runs; pollutant sampling for each run must be conduct ed for the time period specified in the applicable method or, in the absence of a specific time period in the test method, for a minimum of 3 hours. (3) Each emissions test for a batch process must consist of three separate runs; pollutant sampling for each run must be conducted over the entire process operating cycle. (4) Where multiple affected sources or emission units are exhausted through a common stack, pollutant sampling for each run must be conducted over a period of time during which all affected sources or emission units complete at least 1 entire process operating cycle or for 24 hours, whichever is shorter. (5) Initial compliance with an applicable emission limit or standard is demonstrated if the average of three runs conducted during the initial emissions test is less than or equal to th e applicable emiss ion limit or standard. Reference Test Method: EPA RM 5 Monitoring Frequency: SINGLE OCCURRENCE Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 104: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1511(c) , Subpart RRR Item 104.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00002 Item 104.2: Air Po llution Control Permit Conditions Page 124 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator must use the following methods in appendix A to 40 CFR part 60 to determine compliance with the applicable emission limits or standards: (1) Method 1 for sample and velocity traverses. (2) Method 2 for velocity and volumetric flow rate. (3) Method 3 for gas analysis. (4) Method 4 for moisture content of the stack gas. (5) Method 5 for the concentration of PM. (6) Method 9 for visible emission observations. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 105: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1511(e) , Subpart RRR Item 105.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00002 Item 105.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator of new or existing emission units located at secondary aluminum production facilities that are major sources must conduct an emissions test every 5 years following the initial emissions test. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Air Po llution Control Permit Conditions Page 125 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 106: Testing of Representative Emission Units Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1511(f) , Subpart RRR Item 106.1: This Condition applies to Emission Unit: M- 00002 Item 106.2: With the approval of the permitting authority, a sing le representative or similar group 1 furn ace or in-line fluxer which is not controlled by an add-on control device may be tested to determine the emission rate of all like affected sources at a facility provided that: (1) The tested emission unit must use identical feed/charge and flux materials in the same proportions as the emission units that it represents; (2) The tested emission unit is subject to the same work practices and the emissi on units that it represents; (3) The tested emission unit is of the same design as the emission units that it repres ents; (4) The tested emission unit is tested under the highest load or capac ity reasonably expec ted to occur for any of the emission units that it represents; (5) At least one of each different style of emission unit at the facility is tested; and (6) All add-on control devices are tested. Condition 107: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1511(g) , Subpart RRR Item 107.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00002 Item 107.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Establishment of monitoring and operating parameter values. The owner or operator of new or existing emission units must establish a minimum or maximum operating Air Po llution Control Permit Conditions Page 126 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 parameter value, or an operating parameter ra nge for each parameter to be monitored, as required by this permit, that ensures compliance with the applicable emission limit or standard. To establish the minimum or maximum value or range, the owner or operator must use the appropriate procedures in this section and submit the information required by 40 CFR Part 63.1515(b)(4), to the Department . The owner or operator may use existing data in addition to the results of emissions tests to establish operating parameter values for compliance monitoring provided each of the following conditions are met to the satisfaction of the applicable permitting authority: (1) The complete emission test report(s) used as the basis of the parameter(s) is submitted. (2) The same test methods and procedures as required by this subpart were used in the test. (3) The owner or operator certifies that no design or work practice changes have been made to the source, process, or emission control equipment since the time of the report. (4) All process and control equipment operating parameters required to be monitored were monitored as required in this subpart and documented in the test report. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 108: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1512(j), Subpart RRR Item 108.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00002 Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 108.2: Compliance Certification shall include the following monitoring: Air Po llution Control Permit Conditions Page 127 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator must conduct emission tests as described below. The results of the emission tests are used to establish emission rates in lb/ton of feed/charge for PM from each emission unit. These emission rates are used for compliance monito ring in the calculation of the 3-day, 24-hour rolli ng average emission rates using the equation in 40 CFR Part 63.1510(t). An emissions test is required for: (1) Each group 1 furnace tha t processes scrap other than clean charge to measure emissions of PM. (2) Each in-line fluxer to measure emissions of PM. Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 109: Performance Test/Compliance Demonstration Requirements and Procedures - Feed/Charge Weight Measurement. Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1512(k) , Subpart RRR Item 109.1: This Condition applies to Emission Unit: M- 00002 Item 109.2: Feed/charge weight measurement. During the emission tes t(s) conducted to determine compliance with emission limits in a kg/Mg (lb/ton) format, the owner or operator of an affected source or emission unit, subject to an emission limit in a kg/Mg (lb/ton) of feed/charge format, must measure (or otherwise determine) and record the total weight of feed/charge to the affect ed source or emission unit for each of the three test runs and calcu late and record th e total weight. An owner or operator that chooses to demonstrate compliance on the b asis of the aluminum pr oduction weight must measure the weight of aluminum produced by the emission unit or affected source instead of the feed/charge wei ght. Condition 110: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1513(b) , Subpart RRR Item 110.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00002

Air Po llution Control Permit Conditions Page 128 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Item 110.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Use the Equation below to determine the emission rate of PM from the emission unit:

C x Q x K1 E = --------------

P

Where, E = Emission rate of PM, kg/Mg (lb/ton) of feed; C = Concentration of PM, g/dscm (gr/dscf); Q = Volumetric flowrate of exhaust gases, dscm/hr (dscf/hr); K1 = Conversion factor, 1 kg/1, 000 g (1 lb/7,000 gr); and P = Production rate, Mg/hr (ton/hr). Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 111: Equations for Determining Compliance - Secondary Aluminum Processing Unit Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1513(e) , Subpart RRR Item 111.1: This Condition applies to Emission Unit: M- 00002 Item 111.2: Use the procedure below to determine comp liance with emission limits for a sec ondary aluminum processing unit. (1) Use the equation below to compute t he mass-weighted PM emissions for a secondary aluminum processing unit. Compliance is achi eved if the mass-weighted emissions fo r the secondary Air Po llution Control Permit Conditions Page 129 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 aluminum processing unit E CPM is less than or equal to the emission limit for the sec ondary alum inum processing unit L CPM calculated using Equation 1 in 40 CFR Part 63.1505(k).



### E E T

T C ti ti i n

ti i n P M P M



### = ×

=

= 

# ∑ ∑ ( ) ( ) 1

1 Where,
E CPM = The mass-weighted PM emissions for the secondary aluminum processing unit; E tiPM= Measured PM emissions for individual emission unit i; T ti = The average feed rate fo r individual emission unit i during the operating cycle or performance test period; and n=The number of emission units in t he secondary aluminum processing unit. Condition 112: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1517(b)(7 ), Subpart RRR Item 112.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00002 Item 112.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: For each emission unit subject to an emission standard in kg/Mg (lb/ton) of feed/charge, records of feed/charge (or throughput) weights for each operating cycle or time period used in the emissions test. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 113: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.1517(b)( 17), Subpart RRR

Air Po llution Control Permit Conditions Page 130 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Item 113.1: The Compliance Certification ac tivity will be performed for: Emission Unit: M- 00002 Item 113.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: For each secondary aluminum processing unit, records of total charge weight, or if the owner or operator chooses to comply on the basis of aluminum production, total aluminum produced for each 24-hour period and calculations of 3-day, 24- hour rolli ng average emissions. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 114: General requirements Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 226.2 Item 114.1: This Condition applies to Emission Unit: P- 00001 Process: PWS Item 114.2: No person shall conduct solvent metal cleaning unless: (1) Solvent is stored in covered containers and waste solvent is transferred or disposed of in such a manner that less than 20 percent of the waste solvent, by weight, can evaporate into the atmosphere; (2) Equipment used in solvent metal cleaning is maintained to minimize l eaks and fugitive emissions; (3) Equipment used in solvent metal cleaning displays a conspicuous summary of p roper operating procedures consistent with minimizi ng emissions of volatile organic comp ounds; and (4) Equipment covers are closed when the solvent metal cleaning unit is not in service. (5) A record of solvent consumption shall be maintained for each year and made available to the commissioner or his representative upon request. Air Po llution Control Permit Conditions Page 131 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Condition 115: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 226.3(a) Item 115.1: The Compliance Certification ac tivity will be performed for: Emission Unit: P- 00001 Process: PWS Item 115.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Except where otherwise permitted by the commissioner, the following devices are required by a source owner conducting solvent metal cold cleaning degreasing: (1) A cover shall be provided which can be operated easily. (2) The drainage facility shall be internal (under cover), if practical. (3) A control system that limits VOC emissions to those achievable with equipment having a freeboard ratio greater than or equal to 0.7, or a water cover where the solvent is insoluble in and h eavier than water, where the solvent being used has a vapor pressure greater than 33mm Hg at 38° C (100° F) or where the solvent is heated above 50° C (120°F). Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) 

### 46 Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 116: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.9(d)

Air Po llution Control Permit Conditions Page 132 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Item 116.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00001 Process: POT Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 116.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The following equation shall be used to determine permissible solid particulate emissions (based on process weight: for sources up to 100,000 lb/hr - E = 0.024P^(0.67);

where: E - is the permissible emission rate, and P - is process weight in lb/hr.

Reference Test Method: EPA Method 5 Monitoring Frequency: MONTHLY Averaging Method: ANNUAL MAXIMUM ROLLED MONTHLY Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 117: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.843(a)(1 )(i), Subpart LL Item 117.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00001 Process: POT Regulated Contaminant(s): Air Po llution Control Permit Conditions Page 133 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 CAS No: 068188-85-2 FLUORIDES Item 117.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator shall not discharge or cause to be discharged into the atmosphere any emissions of Total Fluorides (TF) in excess of the applicable limit below: - 1.9 lb/ton of aluminum produced for each CWPB1 potline; Monitoring Frequency: MONTHLY Averaging Method: CALENDAR MONTH AVERAGE Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 118: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(d)(1 ), Subpart LL Item 118.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00001 Process: POT Regulated Contaminant(s): CAS No: 068188-85-2 FLUORIDES Item 118.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: The initial performance te st and all subsequent performance tests shall be conducted in accordance with the requirements of the general provisions in 40 CFR Part 63 Subpart A, the approved test plan, and the procedures in 40 CFR Part 63.847. For each potline, the owner or operator shall measure and Air Po llution Control Permit Conditions Page 134 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 record the emission rate of TF exiting the outlet of the primary control system for each potline and the rate of secondary emissions exiting through each roof monitor. Using the equation in 40 CFR Part 63.847(e)(1), the owner or operator shall compute and record the average of at least three runs each month for secondary emissions and at least three runs each year for the primary control system to determine compliance with the applicable emission limit. Compliance is demons trated when the emission rate of TF is equal to or less than the applicable emission limit in 40 CFR Part 63.843(a)(1). Parameter Monitored: FLUORIDES Upper Permit Limit: 1.9 pounds per ton Reference Test Method: EPA RM 13B or ALT Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 119: Performance Test Requirements - Previous Control Device Tests Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(d)(3 ), Subpart LL Item 119.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 119.2: If the owner or operator has performed more than one test of primary emission control devi ce(s) for a potline or for a bake furnace during the previ ous consecutive 12 months, the average of all r uns performed in the previous 12-month period shall be used to determine the contribution from the primary emission control system. Condition 120: Potline TF emission rate calculation Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(e)(1 ), Subpart LL Item 120.1: This Condition applies to Emission Unit: S- 00001 Process: POT Air Po llution Control Permit Conditions Page 135 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Item 120.2: The owner/operator shall determine compliance w ith the applicable TF em ission limits by computing the emission rate (E p ) of TF from each potline using the following equation (Equation 1):

E p = [(C s1 x Q sd ) 1 + (C s2 x Q sd ) 2 ]/(PxK)
Where:
E p =emission rate of TF from a potline, kg/Mg (lb/ton); C s1 =concentration of TF from the prim ary control system, mg/dscm (mg/dscf); Q sd =volumetric flowrate of efflue nt gas corresponding to the appropriate subscript location, dscm/hr (dscf/min); C s2 =concentration of TF as measured for roof monitor emi ssions, mg/dscm (mg/dscf); P=aluminum production rate Mg/hr (ton/hr); K=conversion factor, 10 6 mg/kg (453,600 mg/lb); 1 = subscript for primary control system effluent gas; and 2 =subscript for secondary control system or roof monitor effluent gas
Condition 121: Procedure to determine weights Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(e)(5 ), Subpart LL Item 121.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 121.2: The owner/operator shall determine compliance with the applicable TF and POM em ission limits by determining the weight of th e aluminum tapped from the potline and the weight of the green anode material placed in the anode bake furnace using the monitoring devi ces required in §63. 848(j). Condition 122: Calculation of aluminum production rate Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(e)(6 ), Subpart LL Item 122.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 122.2: The owner/operator shall determine compliance with the applicable TF and POM em ission limits by determining the aluminum production rate (P). This shall be done by dividing the number of hours in the

Air Po llution Control Permit Conditions Page 136 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 calendar month into the weight of aluminum tapped from the potlin e during the calendar month that includes the three runs of a performance test. Condition 123: Selection of monitoring parameters - potlines and anode bake furnaces Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(h)(1 ), Subpart LL Item 123.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 123.2: The owner/operator shall determine the operating limits and monitoring frequency for each control device that is to be monitored as required in §63. 848(f). For po tlines and anode bake furn aces, the owner/operator shall determine upper and/or lower operating limits, as appropriate, for each monitoring device for the emission control system from the values recorded during each of the runs perf ormed during the initial performance test and from historical data from previous performance tests conducted by the methods specified in subpart LL. Condition 124: Selection of monitoring parameters - redetermining operating limits Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(h)(3 ), Subpart LL Item 124.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 124.2: The owner/operator shall determine the operating limits and monitoring frequency for each control device that is to be monitored as required in §63. 848(f). The owner/operator may redetermine the upper and/or lower operating limits, as appropriate, based on historical data or other information and submit an application to the New York Stat e DEC to change the applicable limit(s). The redetermined limits shall become effective upon approval by the New York State DEC. Condition 125: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(a) , Subpart LL Item 125.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00001 Process: POT Air Po llution Control Permit Conditions Page 137 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
Regulated Contaminant(s): CAS No: 068188-85-2 FLUORIDES Item 125.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: Using the procedures in §63. 847 and in the approved test plan, the owner/operator shall monitor emissions of TF from each potline by conducting monthly performance tests. The owner/operator shall compute and record the monthly average from at least three runs for sec ondary emissions and the previous 12-month average of all runs for the primary control system to determine compliance with the applicable emission limit. The owner/operator must include all valid runs in the monthly average. The duration of each run for secondary emissi ons must represent a complete operating cycle. Parameter Monitored: FLUORIDES Upper Permit Limit: 1.9 pounds per ton Reference Test Method: EPA RM 13B or ALT Monitoring Frequency: MONTHLY Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 126: Reduced sampling frequency - contents of request letter Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(e)(1 ), Subpart LL Item 126.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 126.2: The owner/operator may submit a written request to the New York State DEC to establish an alternative testing requirement to reduce the sampling of sec ondary TF emissions from po tlines from monthly to quarterly. In the request, the owner/operator shall provide information and data demonstrating, to the satisfaction of the New York State DEC, thatsecondary emiss ions of TF from potlines have low variability during normal operati ons us ing the following procedures:

Air Po llution Control Permit Conditions Page 138 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 1) Submit data from 24 consecutive months of sampling that show the average TF emissions are less than 60 percent of the applicable limit and that no monthly performance test in the 24 months of sam pling exceeds 75 of the applicable limit; or 2) Submit data and a statistical analysis that the New Yo rk State DEC may evaluatebased on the approach sued in "Primary Aluminum: Statistical Analysis of Potline Fluoride Emissions and Alternative Sampling Frequency" (EPA-450-86-012, October 1986). Condition 127: Reduced sampling frequency request - contents of the approved alternative requirement Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(e)(2 ), Subpart LL Item 127.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 127.2: The owner/operator may submit a written request to the New York State DEC to establish an alternative testing requirement to reduce the sampling of sec ondary TF emissions from po tlines from monthly to quarterly. An approved alternative requirement must include a test schedule and the met hod to be used to m easure emissions for performance tests. Condition 128: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(f)(1 ), Subpart LL Item 128.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00001 Process: POT Regulated Contaminant(s): CAS No: 068188-85-2 FLUORIDES Item 128.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator shall install, operate, calibrate, and maintain a conti nuous parameter monitoring system for each emission control device. The owner/operator shall submit Air Po llution Control Permit Conditions Page 139 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 for approval by the New York State DEC a description of the parameter(s) to be monitored, the operating limits, and the monitoring frequency to ensure that the control device is being properly operated and maintained. An explanation of the criteria used for selection of the parameter(s), the operating limits, and the monitoring frequency, including how t hese relate to emission control also shall be submitted to the New York State DEC. Except as provided in §63.848(l), for dry alumina scrubbers, a device for the measurement of air flow shall be installed, monitored and recorded in accordance with the parametric monitoring plan. Reference Test Method: 4075-TF Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 129: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(f)(1 ), Subpart LL Item 129.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00001 Process: POT Regulated Contaminant(s): CAS No: 068188-85-2 FLUORIDES Item 129.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator shall install, operate, calibrate, and maintain a conti nuous parameter monitoring system for each 20emission control device. The owner/operator shall submit for approval by the New York State DEC a description of the parameter(s) to be monitored, the operating limits, and the monitoring frequency to ensure that the control device is being properly operated and maintained. An explanation of the criteria used for selection of the parameter(s), the operating limits, and the monitoring Air Po llution Control Permit Conditions Page 140 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 frequency, including how t hese relate to emission control also shall be submitted to the New York State DEC. Except as provided in §63.848(l), for dry alumina scrubbers, a device for the measurement of alumina flow shall be installed, monitored and recorded in accordance with the parametric monitoring plan. Reference Test Method: 4075-TF Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 130: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(g) , Subpart LL Item 130.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00001 Process: POT Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 130.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator shall visually inspect the exhaust stack(s) of each control device on a daily basis for evidence of any visible emissions indicating abnormal operation. Monitoring Frequency: DAILY Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 131: Corrective action procedures Effective between the dates of 09/01/2002 and 09/01/2007 Air Po llution Control Permit Conditions Page 141 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
Applicable Federal Requirement: 40CFR 63.848(h) , Subpart LL Item 131.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 131.2: If a monitoring device for a primary control device measures an operating parameter outside the limit(s) established pursuant to §63.847(h), or if visible emissions indicating abnormal operation are observed from the exhaust stack of a control device during a daily inspection, the owner/operator shall initiate the corrective action procedures identified in the startup, shutdown, and malfunction plan within 1 hour. Failure to initiate the correctiv e action procedures within 1 hour or to take the necessary corrective ac tions to remedy the problem is a violation. Condition 132: Exceedances Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(i) , Subpart LL Item 132.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 132.2: If the limit for a given o perating parameter associated with monitoring a specific control device is exceeded six times in any semiannual reporting period, then any subsequent ex ceedance in that reporting period is a violation. For the purpose of determining the number of exceedances, no more than one exceedance shall be attributed in any given 24-hour period. Condition 133: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(j), Subpart LL Item 133.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00001 Process: POT Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Item 133.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Air Po llution Control Permit Conditions Page 142 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Monitoring Description: The owner/operator of a new or existing potline or anode bake furnace shall install, operate, and maintain a monitoring device to determine the daily weight of aluminum produced and the weight of green anode material placed in the anode bake furn ace. The weight of green anode material may be determined by monitoring the weight of all anodes or by monito ring the number of anodes placed in the furnace and determining an average weight from measurements of a representative sample of anodes. Monitoring Frequency: DAILY Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 134: Accuracy and calibration requirements Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(k) , Subpart LL Item 134.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 134.2: The owner/operator shall submit recommended accur acy requirement to the New York State DEC for review and approval. All monitoring devices required by §63. 848 must be certified by the owner/operator to meet the accuracy requirements and must be calibrated in accordance with the manufacturer's instructions. Condition 135: Alternative operating parameters Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(l) , Subpart LL Item 135.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 135.2: The owner/operator may monitor alternative control device operating parameters subj ect to prior written approval by the New York State DEC.

Air Po llution Control Permit Conditions Page 143 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Condition 136: Definition of potline in Method 14 Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.849(c) , Subpart LL Item 136.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 136.2: Except as provided in §63.845(g)(1), references to "potr oom" or "potroom group" in Met hod 14 in appendix A to part 60 shall be interpreted as "potline" for the purposes of subpart LL. Condition 137: Installation of manifolds for potlines subject to Method 14 Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.849(d) , Subpart LL Item 137.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 137.2: For sampling using Method 14 in App endix A to part 60, the owner/operator shall install one Met hod 14 manifold per potline in a potroom that is representative of the entire potline, and this manifold shall meet the installation requirements specified in section 2.2.1 of Method 14 in appendix A to part 60. Condition 138: Performance test reports Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(b) , Subpart LL Item 138.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 138.2: The owner/operator shall report the results of the initial performance test as part of the notification of compliance status required in §63.850(a)(6). Except as p rovided in §63.850(d), the owner/operator shall submit a summary of all subsequent performance tests to the New York State DEC on an annual basis. Condition 139: Startup, shutdown, and malfunction plan and reports Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(c)(1 ), Subpart LL Item 139.1: Air Po llution Control Permit Conditions Page 144 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 This Condition applies to Emission Unit: S- 00001 Process: POT Item 139.2: The owner/operator shall de velop and implement a written plan as described in §63.6(e)(3) t hat contains specific procedures to be followed for operating the source and maintaining the source during periods of startup, shutdown, and malfunction and a progr am of corrective action for malfunc tioning process and control systems used to comply with the standard. The plan does not have to be submitted with the permit application or included in the operating permit. T he New York State DEC may review the plan upon request. In addition to the information required in §63.6(e)(3), the plan shall include procedures, including corrective actions, to be followed if a monitoring device measur es an operating parameter outside the limit(s) established under §63.847(h), or if visible emi ssions from an exhaust stack indicating abnormal operation of a control device are observed by the owner/operator during the daily insp ection required in §63.848(g). Condition 140: Startup, shutdown, and malfunction plan and reports Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(c)(2 ), Subpart LL Item 140.1: This Condition applies to Emission Unit: S- 00001 Process: POT Item 140.2: The owner/operator shall de velop and implement a written plan as described in §63.6(e)(3) t hat contains specific procedures to be followed for operating the source and maintaining the source during periods of startup, shutdown, and malfunction and a progr am of corrective action for malfunc tioning process and control systems used to comply with the standard. The plan does not have to be submitted with the permit application or included in the operating permit. T he New York State DEC may review the plan upon request. In addition to the information required in §63.6(e)(3), the plan shall include records of each event as required by §63.10(b) and the owner/operator shall record and report if an action taken during a startup, shutdown, or malfunction is not consistent with the procedures in the plan as described in §63.6(e)(3)(iv). Condition 141: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(d) , Subpart LL Item 141.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00001 Process: POT Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Air Po llution Control Permit Conditions Page 145 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Item 141.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: As required in §63.10(e)(3), the owner/operator shall submit a report (or a summary report) if measured emissions are in excess of the applicable standard. The report shall contain the information specified in §63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required as a result of excess emissions. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 142: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(e)(1 ), Subpart LL Item 142.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00001 Process: POT Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Item 142.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator shall maintain files of all information (including all reports and notifications) required by §63.10(b) and by Subpart LL. Records must be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The most recent 2 years of records must be retained at the facility. The remaining 3 years of records may be retained offsite. Air Po llution Control Permit Conditions Page 146 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 143: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(e)(2 ), Subpart LL Item 143.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00001 Process: POT Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Item 143.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape, or on microfiche. Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 144: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(e)(3 ), Subpart LL Item 144.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00001 Process: POT Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Item 144.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator may report required information on Air Po llution Control Permit Conditions Page 147 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 paper or on a labeled computer disc using commonly available and compatible computer software. Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 145: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(e)(4 ), Subpart LL Item 145.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00001 Process: POT Item 145.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: In addition to the general records required by §63.10(b), the owner/operator shall main tain records of the following information: 1) Daily production rate of aluminum; 2) A copy of the startup, shutdown, and malfunction plan; 3) Records supporting a request for reduced sampling of potlines; 4) Records, such as a checklist or the equivalent, demonstrating that the daily visual inspection of the exhaust stack for each control device has been performed as required in §63.848(g), inc luding the results of each inspection; 5) Records documenting the co rrective actions taken when the limit(s) for an operating parameter established under §63.847(h) were exceeded, or when visible emiss ions indicating abnormal operation were observed from a control device stack during a daily inspection required under §63.848(g); 6) Records documenting the portion of TF that is measured as particulate matter and the portion that is measured as Air Po llution Control Permit Conditions Page 148 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 gaseous when the particulate and gaseous fractions are quantified separately using an approved test method. Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 146: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.843(c)(1 ), Subpart LL Item 146.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 068188-85-2 FLUORIDES Item 146.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator shall not discharge or cause to be discharged into the atmosphere any emissions of TF in excess of the limit specified below: - TF shall not ex ceed 0.20 lb/ton of green anode. Reference Test Method: EPA Method 13A Monitoring Frequency: ANNUALLY Averaging Method: CALENDAR YEAR AVERAGE Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 147: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.843(c)(2 ), Subpart LL Item 147.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 Air Po llution Control Permit Conditions Page 149 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Process: BAK Regulated Contaminant(s): CAS No: 0NY505-00-0 40 CFR 63 SUBPART LL - POM Item 147.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner or operator shall not discharge or cause to be discharged into the atmosphere any emissions of POM in excess of the limit specified below: - POM shall not ex ceed 0.18 lb/ton of green anode. Reference Test Method: EPA Method 315 Monitoring Frequency: ANNUALLY Averaging Method: CALENDAR YEAR AVERAGE Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 148: Performance Test Requirements - Previous Control Device Tests Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(d)(3 ), Subpart LL Item 148.1: This Condition applies to Emission Unit: S- 00002 Process: BAK Item 148.2: If the owner or operator has performed more than one test of primary emission control devi ce(s) for a potline or for a bake furnace during the previ ous consecutive 12 months, the average of all r uns performed in the previous 12-month period shall be used to determine the contribution from the primary emission control system. Condition 149: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(d)(4 ), Subpart LL Item 149.1: The Compliance Certification ac tivity will be performed for: Air Po llution Control Permit Conditions Page 150 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 0NY505-00-0 40 CFR 63 SUBPART LL - POM Item 149.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: The initial performance te st and all subsequent performance tests shall be conducted in accordance with the requirements of the general provisions in 40 CFR Part 63 Subpart A, the approved test plan, and the procedures in 40 CFR Part 63.847. For each anode bake furnace, the owner or operator shall measure and record the emission rate of POM exiting the exhaust stack(s) of the primary emission control system for each anode bake furnace. Using the equation in 40 CFR Part 63.847(e)(4), the owner or operator shall compute and record the average of at least three runs each year to determine compliance with the applicable emission limit for POM. Compliance is demonstrated when the emission rate of POM is equal to or less than the applicable POM emission limit in 40 CFR Part 63.843(c)(2). n0 Parameter Monitored: 40 CFR 63 SUBPART LL - POM Upper Permit Limit: 0.18 pounds per ton Reference Test Method: EPA RM 315 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 150: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(d)(4 ), Subpart LL Item 150.1: The Compliance Certification ac tivity will be performed for: Air Po llution Control Permit Conditions Page 151 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 068188-85-2 FLUORIDES Item 150.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: The initial performance te st and all subsequent performance tests shall be conducted in accordance with the requirements of the general provisions in 40 CFR Part 63 Subpart A, the approved test plan, and the procedures in 40 CFR Part 63.847. For each anode bake furnace, the owner or operator shall measure and record the emission rate of TF exiting the exhaust stack(s) of the primary emission control system for each anode bake furnace. Using the equation in 40 CFR Part 63.847(e)(3), the owner or operator shall compute and record the average of at least three runs each year to determine compliance with the applicable emission limit for TF. Compliance is demons trated when the emission rate of TF is equal to or less than the applicable TF emission limit in 40 CFR Part 63.843(c)(1). Parameter Monitored: FLUORIDES Upper Permit Limit: 0.20 pounds per ton Reference Test Method: EPA RM 13B or ALT Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 151: Calculation of anode bake furnace TF emission rate Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(e)(3 ), Subpart LL Item 151.1: This Condition applies to Emission Unit: S- 00002 Air Po llution Control Permit Conditions Page 152 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Process: BAK Item 151.2: The owner/operator shall determine compliance w ith the applicable TF em ission limits by computing the emission rate (E b ) from each anode bake furnace using the following equation (Equation 2):

E b = (C s x Q sd ) / (Pb x K)

E b =emission rate of TF, kg/mg (lb/ton) of green anodes produced; C s =concentration of TF, mg/dscm (mg/dscf); Q sd =volumetric flowrate of effluent gas, dscm/hr (dscf/hr); P b =quantity of green anode material pl aced in the furnace, mg/hr (ton/hr); and K = conversion factor, 10 6 mg/kg (453,600 mg/lb) Condition 152: Calculation of anode bake furnace POM emission rate Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(e)(4 ), Subpart LL Item 152.1: This Condition applies to Emission Unit: S- 00002 Process: BAK Item 152.2: The owner/operator shall determine compliance with the applicable POM emi ssion limits by computing the emission rate (Eb) from each anode bake furnace using the following equation (Equation 2): Eb= (Cs x Qsd) / (Pb x K) Eb=emission rate of POM, kg/mg (lb/ton) of green anodes produced; Cs=concentration of POM, mg/dscm (mg/dscf); Qsd=volumetric flowrate of effluent gas, dscm/hr (dscf/hr); Pb=quantity of green anode material placed in the furnace, mg/hr (ton/hr); and K = conversion factor, 106 mg/kg (453,600 mg/lb) Condition 153: Procedure to determine weights Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(e)(5 ), Subpart LL Item 153.1: This Condition applies to Emission Unit: S- 00002 Process: BAK Item 153.2: The owner/operator shall determine compliance with the applicable TF and POM em ission limits by
Air Po llution Control Permit Conditions Page 153 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 determining the weight of th e aluminum tapped from the potline and the weight of the green anode material placed in the anode bake furnace using the monitoring devi ces required in §63. 848(j). Condition 154: Determination of rate of green anode introduction into furnace Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(e)(7 ), Subpart LL



### d Item 154.1: This Condition applies to Emission Unit: S- 00002 Process: BAK Item 154.2: The owner/operator shall determine compliance with the applicable TF and POM em ission limits by calculating the rate that green anode material is introduced into the anode bake furn ace. This shall be determined by dividing the number of operating hours in the calendar month into the weight of green anode material used during the calendar month in which the performance test was conducted. Condition 155: Selection of monitoring parameters - potlines and anode bake furnaces Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(h)(1 ), Subpart LL Item 155.1: This Condition applies to Emission Unit: S- 00002 Process: BAK Item 155.2: The owner/operator shall determine the operating limits and monitoring frequency for each control device that is to be monitored as required in §63. 848(f). For po tlines and anode bake furn aces, the owner/operator shall determine upper and/or lower operating limits, as appropriate, for each monitoring device for the emission control system from the values recorded during each of the runs perf ormed during the initial performance test and from historical data from previous performance tests conducted by the methods specified in subpart LL. Condition 156: Selection of monitoring parameters - redetermining operating limits Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(h)(3 ), Subpart LL Item 156.1: This Condition applies to Emission Unit: S- 00002 Process: BAK

Air Po llution Control Permit Conditions Page 154 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Item 156.2: The owner/operator shall determine the operating limits and monitoring frequency for each control device that is to be monitored as required in §63. 848(f). The owner/operator may redetermine the upper and/or lower operating limits, as appropriate, based on historical data or other information and submit an application to the New York Stat e DEC to change the applicable limit(s). The redetermined limits shall become effective upon approval by the New York State DEC. Condition 157: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(c) , Subpart LL Item 157.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 0NY505-00-0 40 CFR 63 SUBPART LL - POM Item 157.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: Using the procedures in §63. 847 and in the approved test plan, the owner/operator shall monitor POM emissions from each anode bake furnace on an annual basis. The owner/operator shall compute and record the annual average of POM emissions from at least three runs to determine compliance with th e applicable emission limits. The owner/operator must include all valid runs in the annual average. Parameter Monitored: 40 CFR 63 SUBPART LL - POM Upper Permit Limit: 0.18 pounds per ton Reference Test Method: EPA METHOD 315 Monitoring Frequency: ANNUALLY Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 158: Compliance Certification Air Po llution Control Permit Conditions Page 155 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(c) , Subpart LL Item 158.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 068188-85-2 FLUORIDES Item 158.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: Using the procedures in §63. 847 and in the approved test plan, the owner/operator shall monitor TF emissions from each anode bake furnace on an annual basis. The owner/operator shall compute and record the annual average of TF emissions from at least three runs to determine compliance with th e applicable emission limits. The owner/operator must include all valid runs in the annual average. Parameter Monitored: FLUORIDES Upper Permit Limit: 0.20 pounds per ton Monitoring Frequency: ANNUALLY Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 159: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(f)(1 ), Subpart LL Item 159.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 Process: BAK

Air Po llution Control Permit Conditions Page 156 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Regulated Contaminant(s): CAS No: 068188-85-2 FLUORIDES Item 159.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator shall install, operate, calibrate, and maintain a conti nuous parameter monitoring system for each emission control device. The owner/operator shall submit for approval by the New York State DEC a description of the parameter(s) to be monitored, the operating limits, and the monitoring frequency to ensure that the control device is being properly operated and maintained. An explanation of the criteria used for selection of the parameter(s), the operating limits, and the monitoring frequency, including how t hese relate to emission control also shall be submitted to the New York State DEC. Except as provided in §63.848(l), for dry alumina scrubbers, a device for the measurement of air flow shall be installed, monitored and recorded in accordance with the parametric monitoring plan. Reference Test Method: 4075-TF Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 160: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(f)(1 ), Subpart LL Item 160.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 068188-85-2 FLUORIDES Item 160.2: Compliance Certification shall include the following monitoring:

Air Po llution Control Permit Conditions Page 157 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator shall install, operate, calibrate, and maintain a conti nuous parameter monitoring system for each emission control device. The owner/operator shall submit for approval by the New York State DEC a description of the parameter(s) to be monitored, the operating limits, and the monitoring frequency to ensure that the control device is being properly operated and maintained. An explanation of the criteria used for selection of the parameter(s), the operating limits, and the monitoring frequency, including how t hese relate to emission control also shall be submitted to the New York State DEC. Except as provided in §63.848(l), for dry alumina scrubbers, a device for the measurement of alumina flow shall be installed, monitored and recorded in accordance with the parametric monitoring plan. Reference Test Method: 4075-TF Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 161: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(g) , Subpart LL Item 161.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 161.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator shall visually inspect the exhaust stack(s) of each control device on a daily basis for evidence of any visible emissions indicating abnormal operation. Air Po llution Control Permit Conditions Page 158 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
Monitoring Frequency: DAILY Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 162: Corrective action procedures Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(h) , Subpart LL Item 162.1: This Condition applies to Emission Unit: S- 00002 Process: BAK Item 162.2: If a monitoring device for a primary control device measures an operating parameter outside the limit(s) established pursuant to §63.847(h), or if visible emissions indicating abnormal operation are observed from the exhaust stack of a control device during a daily inspection, the owner/operator shall initiate the corrective action procedures identified in the startup, shutdown, and malfunction plan within 1 hour. Failure to initiate the correctiv e action procedures within 1 hour or to take the necessary corrective ac tions to remedy the problem is a violation. Condition 163: Exceedances Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(i) , Subpart LL Item 163.1: This Condition applies to Emission Unit: S- 00002 Process: BAK Item 163.2: If the limit for a given o perating parameter associated with monitoring a specific control device is exceeded six times in any semiannual reporting period, then any subsequent ex ceedance in that reporting period is a violation. For the purpose of determining the number of exceedances, no more than one exceedance shall be attributed in any given 24-hour period. Condition 164: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(j), Subpart LL Item 164.1: The Compliance Certification ac tivity will be performed for: Air Po llution Control Permit Conditions Page 159 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Item 164.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator of a new or existing potline or anode bake furnace shall install, operate, and maintain a monitoring device to determine the daily weight of aluminum produced and the weight of green anode material placed in the anode bake furn ace. The weight of green anode material may be determined by monitoring the weight of all anodes or by monito ring the number of anodes placed in the furnace and determining an average weight from measurements of a representative sample of anodes. Monitoring Frequency: DAILY Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 165: Accuracy and calibration requirements Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(k) , Subpart LL Item 165.1: This Condition applies to Emission Unit: S- 00002 Process: BAK Item 165.2: The owner/operator shall submit recommended accur acy requirement to the New York State DEC for review and approval. All monitoring devices required by §63. 848 must be certified by the owner/operator to meet the accuracy requirements and must be calibrated in accordance with the manufacturer's instructions. Condition 166: Alternative operating parameters Effective between the dates of 09/01/2002 and 09/01/2007

Air Po llution Control Permit Conditions Page 160 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Applicable Federal Requirement: 40CFR 63.848(l) , Subpart LL Item 166.1: This Condition applies to Emission Unit: S- 00002 Process: BAK Item 166.2: The owner/operator may monitor alternative control device operating parameters subj ect to prior written approval by the New York State DEC. Condition 167: Performance test reports Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(b) , Subpart LL Item 167.1: This Condition applies to Emission Unit: S- 00002 Process: BAK Item 167.2: The owner/operator shall report the results of the initial performance test as part of the notification of compliance status required in §63.850(a)(6). Except as p rovided in §63.850(d), the owner/operator shall submit a summary of all subsequent performance tests to the New York State DEC on an annual basis. Condition 168: Startup, shutdown, and malfunction plan and reports Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(c)(1 ), Subpart LL Item 168.1: This Condition applies to Emission Unit: S- 00002 Process: BAK Item 168.2: The owner/operator shall de velop and implement a written plan as described in §63.6(e)(3) t hat contains specific procedures to be followed for operating the source and maintaining the source during periods of startup, shutdown, and malfunction and a progr am of corrective action for malfunc tioning process and control systems used to comply with the standard. The plan does not have to be submitted with the permit application or included in the operating permit. T he New York State DEC may review the plan upon request. In addition to the information required in §63.6(e)(3), the plan shall include procedures, including corrective actions, to be followed if a monitoring device measur es an operating parameter outside the limit(s) established under §63.847(h), or if visible emi ssions from an exhaust stack indicating abnormal operation of a control device are observed by the owner/operator during the daily insp ection required in §63.848(g). Condition 169: Startup, shutdown, and malfunction plan and reports Effective between the dates of 09/01/2002 and 09/01/2007

Air Po llution Control Permit Conditions Page 161 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Applicable Federal Requirement: 40CFR 63.850(c)(2 ), Subpart LL Item 169.1: This Condition applies to Emission Unit: S- 00002 Process: BAK Item 169.2: The owner/operator shall de velop and implement a written plan as described in §63.6(e)(3) t hat contains specific procedures to be followed for operating the source and maintaining the source during periods of startup, shutdown, and malfunction and a progr am of corrective action for malfunc tioning process and control systems used to comply with the standard. The plan does not have to be submitted with the permit application or included in the operating permit. T he New York State DEC may review the plan upon request. In addition to the information required in §63.6(e)(3), the plan shall include records of each event as required by §63.10(b) and the owner/operator shall record and report if an action taken during a startup, shutdown, or malfunction is not consistent with the procedures in the plan as described in §63.6(e)(3)(iv). Condition 170: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(d) , Subpart LL Item 170.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Item 170.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: As required in §63.10(e)(3), the owner/operator shall submit a report (or a summary report) if measured emissions are in excess of the applicable standard. The report shall contain the information specified in §63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required as a result of excess emissions. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. Air Po llution Control Permit Conditions Page 162 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 171: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(e)(1 ), Subpart LL Item 171.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Item 171.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator shall maintain files of all information (including all reports and notifications) required by §63.10(b) and by Subpart LL. Records must be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The most recent 2 years of records must be retained at the facility. The remaining 3 years of records may be retained offsite. Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 172: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(e)(2 ), Subpart LL Item 172.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Item 172.2: Air Po llution Control Permit Conditions Page 163 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape, or on microfiche. Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 173: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(e)(3 ), Subpart LL Item 173.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Item 173.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator may report required information on paper or on a labeled computer disc using commonly available and compatible computer software. Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 174: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(e)(4 ), Subpart LL Item 174.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 0 Process: BAK Item 174.2: Compliance Certification shall include the following monitoring: Air Po llution Control Permit Conditions Page 164 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: In addition to the general records required by §63.10(b), the owner/operator shall main tain records of the following information: 1) Daily production rate of gr een anode material placed in the anode bake furnace; 2) A copy of the startup, shutdown, and malfunction plan; 3) Records, such as a checklist or the equivalent, demonstrating that the daily visual inspection of the exhaust stack for each control device has been performed as required in §63.848(g), inc luding the results of each inspection; 4) Records documenting the co rrective actions taken when the limit(s) for an operating parameter established under §63.847(h) were exceeded, or when visible emiss ions indicating abnormal operation were observed from a control device stack during a daily inspection required under §63.848(g); 5) Records documenting the portion of TF that is measured as particulate matter and the portion that is measured as gaseous when the particulate and gaseous fractions are quantified separately using an approved test method. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 175: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.10(c)(3) Item 175.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 Emission Point: S0078 Process: BAK Emission Source: SS078 Regulated Contaminant(s): CAS No: 0NY998-00-0 VOC Air Po llution Control Permit Conditions Page 165 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Item 175.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: Control of VOC emissions from this source were shown to be technically infeasible in the RACT analysis submitted to the Department in September of 1998. The Alumina dry scrubber will continue to be operated and reported under the guidelines of 40 CFR 63 Subpart LL for Primary Aluminum Production. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 176: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.10(c)(3) Item 176.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00002 Emission Point: S0078 Process: BAK Emission Source: SS078 Regulated Contaminant(s): CAS No: 0NY210-00-0 OXIDES OF NITROGEN Item 176.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The NOx RACT Compliance Pl an submitted to NYSDEC in 1994 determined that control of NOx is not technically feasible due to the nature and conf iguration of the anode bake furnace burners. Thus the current equipment configuration is considered RACT. Monitoring consists of re-certification that the fuel used during the previous reporting period was natural gas. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. Air Po llution Control Permit Conditions Page 166 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 177: Emission Limits for Existing Sources - Paste Production Plants Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.843(b) , Subpart LL Item 177.1: This Condition applies to Emission Unit: S- 00003 Item 177.2: The owner or operator shall install, o perate, and maintain equi pment to capture and control POM emissions from each paste production plant. (1) The emission capture system shall be ins talled and operated to meet the generally accepted engineering standards for minimum exhaust rates as published by the American Conference of Governmental Industrial Hygienists in Chapters 3 and 5 of ``Industrial Ventilation: A Handb ook of Recommended Practice'' (incorporated by reference in Sec. 63.841 of this part); and (2) Captured emissions shall be routed through a closed system to a dry coke scrubber. Condition 178: Initial compliance provisions for paste production plants Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(f) , Subpart LL Item 178.1: This Condition applies to Emission Unit: S- 00003 Item 178.2: Initial compliance with the standards for ex isting and new paste production plants in §§63. 843(b) and 63.844(b) w ill be demonstrated through site inspection(s) and review of site records by the applicable regulatory authority. Condition 179: Selection of monitoring parameters - paste production plants Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(h)(2 ), Subpart LL Item 179.1: This Condition applies to Emission Unit: S- 00003 Item 179.2: The owner/operator shall determine the operating limits and monitoring frequency for each control device that is to be monitored as required in §63. 848(f). For a paste pr oduction plant, the owner/operator shall Air Po llution Control Permit Conditions Page 167 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 specify and provide the basis or rationale for selecting parameters to be monitored and the associated operating limits for the emission control device. Condition 180: Selection of monitoring parameters - redetermining operating limits Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.847(h)(3 ), Subpart LL Item 180.1: This Condition applies to Emission Unit: S- 00003 Item 180.2: The owner/operator shall determine the operating limits and monitoring frequency for each control device that is to be monitored as required in §63. 848(f). The owner/operator may redetermine the upper and/or lower operating limits, as appropriate, based on historical data or other information and submit an application to the New York Stat e DEC to change the applicable limit(s). The redetermined limits shall become effective upon approval by the New York State DEC. Condition 181: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(f)(2 ), Subpart LL Item 181.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00003 Regulated Contaminant(s): CAS No: 0NY505-00-0 40 CFR 63 SUBPART LL - POM Item 181.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator shall install, operate, calibrate, and maintain a conti nuous parameter monitoring system for each emission control device. The owner/operator shall submit for approval by the New York State DEC a description of the parameter(s) to be monitored, the operating limits, and the monitoring frequency to ensure that the control device is being properly operated and maintained. An explanation of the criteria used for selection of the parameter(s), the operating limits, and the monitoring frequency, including how t hese relate to emission control also shall be submitted to the New York State Air Po llution Control Permit Conditions Page 168 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 DEC. Except as provided in §63.848(l), for dry coke scrubbers, a device for the measurement of air flow shall be installed, monitored and recorded in accordance with the parametric monitoring plan. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 182: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(f)(2 ), Subpart LL Item 182.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00003 Regulated Contaminant(s): CAS No: 0NY505-00-0 40 CFR 63 SUBPART LL - POM Item 182.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator shall install, operate, calibrate, and maintain a conti nuous parameter monitoring system for each emission control device. The owner/operator shall submit for approval by the New York State DEC a description of the parameter(s) to be monitored, the operating limits, and the monitoring frequency to ensure that the control device is being properly operated and maintained. An explanation of the criteria used for selection of the parameter(s), the operating limits, and the monitoring frequency, including how t hese relate to emission control also shall be submitted to the New York State DEC. Except as provided in §63.848(l), for dry coke scrubbers, a device for the measurement of coke flow shall be installed, monitored and recorded in accordance with the parametric monitoring plan. Monitoring Frequency: AS REQUIRED - SEE MONITORING Air Po llution Control Permit Conditions Page 169 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 183: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(g) , Subpart LL Item 183.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00003 Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 183.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator shall visually inspect the exhaust stack(s) of each control device on a daily basis for evidence of any visible emissions indicating abnormal operation. Monitoring Frequency: DAILY Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 184: Corrective action procedures Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(h) , Subpart LL Item 184.1: This Condition applies to Emission Unit: S- 00003 Item 184.2: If a monitoring device for a primary control device measures an operating parameter outside the limit(s) established pursuant to §63.847(h), or if visible emissions indicating abnormal operation are observed from the exhaust stack of a control device during a daily inspection, the owner/operator shall initiate the corrective action procedures identified in the startup, shutdown, and malfunction plan within 1 hour. Failure to initiate the correctiv e action procedures within 1 hour or to take the necessary corrective ac tions to remedy the problem is a violation.

Air Po llution Control Permit Conditions Page 170 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Condition 185: Exceedances Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(i) , Subpart LL Item 185.1: This Condition applies to Emission Unit: S- 00003 Item 185.2: If the limit for a given o perating parameter associated with monitoring a specific control device is exceeded six times in any semiannual reporting period, then any subsequent ex ceedance in that reporting period is a violation. For the purpose of determining the number of exceedances, no more than one exceedance shall be attributed in any given 24-hour period. Condition 186: Accuracy and calibration requirements Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(k) , Subpart LL Item 186.1: This Condition applies to Emission Unit: S- 00003 Item 186.2: The owner/operator shall submit recommended accur acy requirement to the New York State DEC for review and approval. All monitoring devices required by §63. 848 must be certified by the owner/operator to meet the accuracy requirements and must be calibrated in accordance with the manufacturer's instructions. Condition 187: Alternative operating parameters Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.848(l) , Subpart LL Item 187.1: This Condition applies to Emission Unit: S- 00003 Item 187.2: The owner/operator may monitor alternative control device operating parameters subj ect to prior written approval by the New York State DEC. Condition 188: Startup, shutdown, and malfunction plan and reports Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(c)(1 ), Subpart LL Item 188.1: This Condition applies to Emission Unit: S- 00003

Air Po llution Control Permit Conditions Page 171 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Item 188.2: The owner/operator shall de velop and implement a written plan as described in §63.6(e)(3) t hat contains specific procedures to be followed for operating the source and maintaining the source during periods of startup, shutdown, and malfunction and a progr am of corrective action for malfunc tioning process and control systems used to comply with the standard. The plan does not have to be submitted with the permit application or included in the operating permit. T he New York State DEC may review the plan upon request. In addition to the information required in §63.6(e)(3), the plan shall include procedures, including corrective actions, to be followed if a monitoring device measur es an operating parameter outside the limit(s) established under §63.847(h), or if visible emi ssions from an exhaust stack indicating abnormal operation of a control device are observed by the owner/operator during the daily insp ection required in §63.848(g). Condition 189: Startup, shutdown, and malfunction plan and reports Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(c)(2 ), Subpart LL Item 189.1: This Condition applies to Emission Unit: S- 00003 Item 189.2: The owner/operator shall de velop and implement a written plan as described in §63.6(e)(3) t hat contains specific procedures to be followed for operating the source and maintaining the source during periods of startup, shutdown, and malfunction and a progr am of corrective action for malfunc tioning process and control systems used to comply with the standard. The plan does not have to be submitted with the permit application or included in the operating permit. T he New York State DEC may review the plan upon request. In addition to the information required in §63.6(e)(3), the plan shall include records of each event as required by §63.10(b) and the owner/operator shall record and report if an action taken during a startup, shutdown, or malfunction is not consistent with the procedures in the plan as described in §63.6(e)(3)(iv). Condition 190: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(d) , Subpart LL Item 190.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00003 Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Item 190.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Air Po llution Control Permit Conditions Page 172 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Monitoring Description: As required in §63.10(e)(3), the owner/operator shall submit a report (or a summary report) if measured emissions are in excess of the applicable standard. The report shall contain the information specified in §63.10(e)(3)(v) and be submitted semiannually unless quarterly reports are required as a result of excess emissions. Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 191: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(e)(1 ), Subpart LL Item 191.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00003 Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Item 191.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator shall maintain files of all information (including all reports and notifications) required by §63.10(b) and by Subpart LL. Records must be retained for at least 5 years following the date of each occurrence, measurement, maintenance, corrective action, report, or record. The most recent 2 years of records must be retained at the facility. The remaining 3 years of records may be retained offsite. Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 192: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(e)(2 ), Subpart LL

Air Po llution Control Permit Conditions Page 173 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Item 192.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00003 Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Item 192.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator may retain records on microfilm, on a computer, on computer disks, on magnetic tape, or on microfiche. Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 193: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(e)(3 ), Subpart LL Item 193.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00003 Regulated Contaminant(s): CAS No: 0NY100-00-0 HAP Item 193.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The owner/operator may report required information on paper or on a labeled computer disc using commonly available and compatible computer software. Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 194: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 63.850(e)(4 ), Subpart LL

Air Po llution Control Permit Conditions Page 174 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Item 194.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00003 Item 194.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: In addition to the general records required by §63.10(b), the owner/operator shall main tain records of the following information: 1) A copy of the startup, shutdown, and malfunction plan; 2) Records of design information for paste production plant capture systems; 3) Records, such as a checklist or the equivalent, demonstrating that the daily visual inspection of the exhaust stack for each control device has been performed as required in §63.848(g), inc luding the results of each inspection; 4) Records documenting the co rrective actions taken when the limit(s) for an operating parameter established under §63.847(h) were exceeded, or when visible emiss ions indicating abnormal operation were observed from a control device stack during a daily inspection required under §63.848(g). Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 195: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.10(f) Item 195.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00003 Emission Point: S0100 Regulated Contaminant(s): Air Po llution Control Permit Conditions Page 175 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 CAS No: 0NY998-00-0 VOC Item 195.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: This source must be operated in such a manner to achieve an overall volatileorganic comp ound (VOC) re moval efficiency of at least 81%. For the purposes of determining compliance with this condition emissions of polycyclic organic matter (POM) shall be included in the total VOC emissions from the source. Lower Permit Lim it: 81 percent Reference Test Method: 18 or 25A and 315 Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 196: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.3(b) Item 196.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00004 Process: M01 Emission Source: SS017 Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 196.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: Emissions of solid particulates are limited to less than 0.150 grains of particulates per cubic foot of exhaust gas, expressed at standard conditions on a dry gas basis. Compliance testing will be conducted at th e discretion of the Department. Air Po llution Control Permit Conditions Page 176 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

Parameter Monitored: PARTICULATES Upper Permit Limit: 0.15 grains per dscf Reference Test Method: EPA Method 5 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 197: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 40CFR 52.21(i)(1), Subpart A Item 197.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00004 Process: M16 Regulated Contaminant(s): CAS No: 0NY075-00-0 PARTICULATES Item 197.2: Compliance Certification shall include the following monitoring: Capping: Yes Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: Particulate emissions from this emission source shall not exceed 15 tons during any 12 month period. Source owner must maintain records that demonstrate compliance with this emission limit. R ecords should incl ude: any stack test reports, the number of hours the spent potliner handling is being performed, the number of hours that the baghouse is not in operati on while spent potliner handling is occurring, and information that shows the baghouse is being operate d with the manufact urer's specificati ons for pressure drop and air/cloth ratio. Upper Permit Limit: 15 tons per year Reference Test Method: EPA RM 5 Monitoring Frequency: ONCE DURING THE TERM OF THE PERMIT Averaging Method: ANNUAL MAXIMUM ROLLED MONTHLY Air Po llution Control Permit Conditions Page 177 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 198: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.10(c)(1) Item 198.1: The Compliance Certification ac tivity will be performed for: Emission Unit: S- 00005 Process: PST Regulated Contaminant(s): CAS No: 0NY998-00-0 VOC Item 198.2: Compliance Certification shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The emission rate potential of volatileorganic compound (VOC) from each emission point in this process shall remain less than 3.0 pounds per hour. A reasonably available control technology (RACT) analysis is not required for emission points with VOC emission rate potentials less than 3.0 pounds per hour at facilities located outside of the Low er Orange County and New York City metropolitan areas. While unloading pitch from rail cars the vent from the tank receiving the pitch must be vented to the other pitch storage tank which must be empty. The empty tank will in effect be a condenser for the semi-volatile pitch fumes emitted during the pitch rail car unloading. Failure to operate this process in this manner may cause VOC emissions greater than 3.0 pounds per hour. Reference Test Method: EPA RM 18 or 25A Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. Air Po llution Control Permit Conditions Page 178 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s). Condition 199: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.4(a) Item 199.1: The Compliance Certification ac tivity will be performed for: Emission Unit: W- 00001 Process: WWT Regulated Contaminant(s): CAS No: 000074-90-8 HYDROCYANIC ACID Item 199.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: As required by 6 NYCRR Part 212.4(a) hydrogen cyanide has been issued an environmental rating of A. The emission rate potential of hydrogen cyanide from each emission source in this process shall remain less than 1 pound per hour. Compliance testing sh all be conducted upon request from the Department. Upper Permit Limit: 1. 0 pounds per hour Reference Test Method: EPA Method 18 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: 1-HOUR AVERAGE Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 200: Compliance Certification Effective between the dates of 09/01/2002 and 09/01/2007 Applicable Federal Requirement: 6NYCRR 212.4(a) Item 200.1: The Compliance Certification ac tivity will be performed for: Emission Unit: W- 00001 Process: WWT Regulated Contaminant(s): Air Po llution Control Permit Conditions Page 179 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 CAS No: 007664-41-7 AMMONIA Item 200.2: Compliance Certification shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: As required by 6 NYCRR Part 212.4(a) ammonia has been issued an environmental rating of C. The emission rate potential of ammonia from each emission source in this process shall remain less than 10 pounds per hour. Compliance testing shall be conducted upon request from the Department. Upper Permit Limit: 10 pounds per hour Reference Test Method: EPA CTM-027 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY

Air Po llution Control Permit Conditions Page 180 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003

STATE ONLY ENFORCEABLE CONDITIONS ** ** Facility L evel  

NOTIFICATION OF GENERAL PERMITTEE OBLIGATIONS This section contains terms and conditions wh ich are not federally enforceable. Permittees may also have other obligations under regulations of general applicability Item A: General Provisions for State Enforceable Permit Terms and Condition - 6 NYCRR Part 201-5 Any person who owns and/or o perates stationary sources shall operate and maintain all emission units and any required emission control devi ces in compliance with all applicable Parts of this Ch apter and existing laws, and shall operate the facility in accordance with all criteria, emission limits, terms, conditions, and standards in this permit. Failure of such person to properly operate and maintain the effectiveness of such emission units and emission control devices may be sufficient reason for the Department to revoke or deny a permit. The owner or operator of the permitted facility must maintain all required records on-site for a period of five years and make them available to representatives of the Department upon request. Department representatives must be granted access to any facility regulated by this Subpart, during normal operating hours, for the purpose of determining compliance with this and any other state and federal air pollution control requirements, regulations or law.

STATE ONLY APPLICABLE RE QUIREMENTS The following conditions are state only enforceable and are not subject to annual compliance certification requirements for Title V permits.

Condition 201: Contaminant List Effective between the dates of 09/01/2002 and 09/01/2007 Applicable State Requirement: ECL 19-301. Item 201.1: Emissions of the following contaminants are subject to contaminant specific requirements in this permit(emission limits, control requirements or compliance monitoring conditions).

Air Po llution Control Permit Conditions Page 181 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 CAS No: 0NY505-00-0 Name: 40 CFR 63 SUBPART LL - POM CAS No: 007664-41-7 Name: AMMONIA CAS No: 000630-08-0 Name: CARBON MONOXIDE CAS No: 000463-58-1 Name: CARBONYL SULFIDE CAS No: 007782-50-5 Name: CHLORINE CAS No: 000111-42-2Name: ETHANOL, 2,2'-IMINOBISCAS No: 068188-85-2 Name: FLUORIDES CAS No: 000050-00-0 Name: FORMALDEHYDE CAS No: 0NY100-00-0 Name: HAP CAS No: 000074-90-8 Name: HYDROCYANIC ACID CAS No: 007647-01-0 Name: HYDROGEN CHLORIDE CAS No: 007664-39-3 Name: HYDROGEN FLUORIDE CAS No: 007439-92-1 Name: LEAD CAS No: 000067-56-1 Name: METHYL ALCOHOL CAS No: 0NY210-00-0 Name: OXIDES OF NITROGEN CAS No: 0NY075-00-0 Name: PARTICULATES

Air Po llution Control Permit Conditions Page 182 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 CAS No: 007446-09-5 Name: SULFUR DIOXIDE CAS No: 0NY998-00-0 Name: VOC Condition 202: Unavoidable noncompliance and violations Effective between the dates of 09/01/2002 and 09/01/2007 Applicable State Requirement: 6NYCRR 201-1.4 Item 202.1: At the discretion of the commissioner a violation of any applicable emission standard for n ecessary scheduled equipment maintenance, start-up/shutdown conditions and malfunctions or upsets may be excused if such violations are unavoidable. The following actions and recordkeeping and reporting requirements must be adhered to in such circumstances. (a) The facility owner and/or operator sha ll compile and maintain records of all equipment maintenance or start-up/shutdown activities when th ey can be expected to result in an exceedance of any applicable emission standard, and shall submit a report of such activities to the commissioner's representative when requested to do so in writing or when so required by a condition of a permit issued for the corresponding air contam ination source except where c onditions elsewhere in this permit which contain more stringent reporting and notification provisions for an applicable requirement, in which case they supercede those stated here. Such reports shall describe why the violation was unavoidable and shall include the time, frequency and duration of the maintenance and/or star t-up/shutdown activities and the identification of air contaminants, and the estimated emission rates. If a facility owner and/or operator is subject to conti nuous stack m onitoring and quarterly reporting requirements, he need not submit reports for equipment maintenance or start-up/shutdown for the facility to the commissioner's representative. (b) In the event that emi ssions of air contaminants in excess of any emission standard in 6 NYCRR Chapter III Subchapter A occur due to a malfunction, the facility owner and/or operator shall report such malfunction by telephone to the commissioner's re presentative as soon as possible during normal wo rking hours, but in any event not later than two working days after becoming aware that the malf unction occurred. Within 30 days thereaf ter, when requested in writing by the commissioner's re presentative, the facility owner and/or operator shall submit a written report to the commissioner's representative describing the malfunction, the corrective action taken, identification of air cont aminants, and an estimate of the emission rates. These repo rting requirements are superceded by conditions el sewhere in this permit which contain reporting and notification provisions for applicable requirements more stringent than those above. (c) The Department may also require the owner and/or operator to include in reports described under (a) and (b) above an estimate of the maximum ground level concentration of each air contaminant emitted and the effect of s uch emissions depending on the deviation of the malfunction and the air contaminants emitted. (d) In the event of maintenance, st art-up/ shutdown or ma lfunction conditions which result in emissions exceeding any appli cable emission standard, the fac ility ow ner and/or o perator shall take appropriate action to prevent emissions which w ill re sult in contravention of any applicable ambient air Air Po llution Control Permit Conditions Page 183 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 quality standard. Reasonably available control technology, as determined by the commissioner,. shall be applied during any maintenance, st art-up/ shutdown or ma lfunction condition subject to this paragraph. (e) In order to have a violation of a federal regulation (such as a new source performa nce standard or national emissi ons standa rd for h azardous air p ollutants) excused, the specific federal regulation must provide for an affirmative defense during start-up, shutdowns, malfunctions or upsets. Condition 203: Compliance Demonstration Effective between the dates of 09/01/2002 and 09/01/2007 Applicable State Requirement: 6NYCRR 209. Item 203.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: S- 00001 Process: POT Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 0NY505-00-0 40 CFR 63 SUBPART LL - POM CAS No: 068188-85-2 FLUORIDES Item 203.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: RECORD KEEPING/MAINTENANCE PROCEDURES Monitoring Description: The more stringent requirements of 40 CFR 63 subpart LL apply to the emissions of Fluorides, Po lycyclic Organic Matter (POMs) and opacity at this facility . As long as the facility is in compliance withthe requirements in subpart LL, then it is in compliance with the requirements of 6 NYCRR part 209. See subpart LL requirements for monitoring and reporting frequencies. Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Reporting Requirements: AS REQUIRED - SEE MONITORING DESCRIPTION Condition 204: Emissions other than total fluorides Effective between the dates of 09/01/2002 and 09/01/2007 Applicable State Requirement: 6NYCRR 209.4

Air Po llution Control Permit Conditions Page 184 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Item 204.1: Emissions of air contaminants other than total fluorides from any air contamination source in a primary aluminum reduction plant are regulated by all other applicable Parts of this Subchapter. Condition 205: Air pollution prohibited Effective between the dates of 09/01/2002 and 09/01/2007 Applicable State Requirement: 6NYCRR 211.2 Item 205.1: No person shall cause or allow emissions of air contaminants to the outdoor atmosphere of such quantity, characteristic or duration which are injurious to human, plant or animal life or to property, or which unreasonably interfere with the comf ortable enjoyment of life or prope rty. Notwithstanding the existence of specific air quality s tandards or emission limits, this prohibition applies, but is not limited to, any particulate, fume, gas, mist, odor, smoke, vapor, pollen, toxic or deleterious emission, either alone or in combination with others. Condition 206: Compliance Demonstration Effective between the dates of 09/01/2002 and 09/01/2007 Applicable State Requirement: 6NYCRR 212.4(a) Item 206.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: A- 00001 Process: HMO Emission Unit: A- 00001 Process: HT1 Emission Unit: A- 00001 Process: HT2 Emission Source: AF014 Emission Unit: A- 00001 Process: HT2 Emission Source: AF015 Emission Unit: A- 00001 Process: HT2 Emission Source: AF02A Emission Unit: A- 00001 Process: HT2 Emission Source: AF02B Regulated Contaminant(s): CAS No: 007664-39-3 HYDROGEN FLUORIDE Item 206.2: Air Po llution Control Permit Conditions Page 185 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Compliance Demonstration shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: As required by 6 NYCRR 212.4(a), Hydrogen Fluoride has been issued an environmental rating of "B". The emission rate potential of Hydrogen Fluoride from each of these emission sources shall remain less than 10 pounds per hour. Compliance testing sh all be conducted upon request from the Department. Upper Permit Limit: 10 pounds per hour Reference Test Method: method 4075-TF Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 207: Compliance Demonstration Effective between the dates of 09/01/2002 and 09/01/2007 Applicable State Requirement: 6NYCRR 212.4(a) Item 207.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: C- 00002 Process: CD2 Emission Unit: M- 00001 Emission Unit: M- 00002 Emission Unit: C- 00001 Process: CD1 Regulated Contaminant(s): CAS No: 007647-01-0 HYDROGEN CHLORIDE Item 207.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: As required by 6 NYCRR 212.4(a), Hydrogen Chloride has been issued an environmental rating of "B". The emission Air Po llution Control Permit Conditions Page 186 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 rate potential of Hydrogen Chloride from each of these emission sources shall remain less than 10 pounds per hour. Upper Permit Limit: 10 pounds per hour Reference Test Method: EPA method 26 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST 20 METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 208: Compliance Demonstration Effective between the dates of 09/01/2002 and 09/01/2007 Applicable State Requirement: 6NYCRR 212.5(d) Item 208.1: The Compliance Demonstration activity will be performed for the facility: The Compliance Demonstration applies to: Emission Unit: S- 00001 Process: POT Emission Unit: S- 00002 Process: BAK Regulated Contaminant(s): CAS No: 000463-58-1 CARBONYL SULFIDE CAS No: 000630-08-0 CARBON MONOXIDE CAS No: 007446-09-5 SULFUR DIOXIDE Item 208.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: WORK PRACTICE INVOLVING SPECIFIC OPERATIONS Monitoring Description: Where a source owner can demonstrate to the satisfaction of the commissioner that hewill apply best available control technology (BACT), the commissioner may specify a less restrictive permissible emission rate, emission standard or degree of air cleaning for such source than required under this Part provided that the less restrictive requirement is equivalent to that which can be achieved through the applicati on of best available control technology.

Air Po llution Control Permit Conditions Page 187 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 Carbon Monoxide (CO), Carbonyl Sulfide (COS), and Sulfur Dioxide (SO2) emissions from the anode bake furnace and the potline shall be controlled according to the BACT analysis submitted to the Department July 9, 2001 and approved by Albany staff. The specification of % sulfur by weight in th e coke used at the plant shall be lowered from 3% to 2.5% on an annual average basis rolled monthly. The sulfur content shall be determined from vendor test data for each delivery of coke. The current annual average and any excursions above the limit shall be reported semiannually on a calendar year basis. Work Practice Type: PARAMETER OF PROCESS MATERIAL Process Material: COKE Parameter Monitored: SULFUR Upper Permit Limit: 2.5 percent by weight Monitoring Frequency: MONTHLY Averaging Method: AVERAGING METHOD - SEE MONITORING DESCRIPTION Reporting Requirements: SEMI-ANNUALLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 1/30/03. Subsequent reports are due every 6 calendar mont h(s).

** ** Em ission Unit Level **** Condition 209: Compliance Demonstration Effective between the dates of 09/01/2002 and 09/01/2007 Applicable State Requirement: 6NYCRR 227-1.4(a) Item 209.1: The Compliance Demonstration activity will be performed for: Emission Unit: B- 00001 Process: OIL Item 209.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: MONITORING OF PROCESS OR CONTROL DEVICE PARAMETERS AS SURROGATE Monitoring Description: Any person who owns a stationary combustion installation Air Po llution Control Permit Conditions Page 188 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 (excluding gas turbines), with a total maximum heat input capacity exceeding 250 m illion Btu per hour shall install, operate in accordance with manufacturer's instructions, and properly maintain, accurate instruments satisfying the criteria in appendix B of title 40, part 60 of the Code of Federal Regulations, or approved by the commissioner on an individual case basis, for continuously monitoring and recording opacity, and when sulfur dioxide conti nuous monitoring is required by Part 225 of this T itle, for continuously monitoring and recording either the percent oxygen or carbon dioxide in the flue gases from such installations at all tim es that the combustion installation is in service. Where gas is the only fuel burned, monitoring and recording of opacity is not required. Parameter Monitored: OPACITY Upper Permit Lim it: 20 percent Reference Test Method: Apendix B, 40 CFR 60 Monitoring Frequency: CONTINUOUS Averaging Method: 6 MINUTE AVERAGE Reporting Requirements: QUARTERLY (CALENDAR) Reports due 30 days after the reporting period. The initial report is due 10/30/02. Subsequent reports are due every 3 calendar mont h(s). Condition 210: Compliance Demonstration Effective between the dates of 09/01/2002 and 09/01/2007 Applicable State Requirement: 6NYCRR 212.4(a) Item 210.1: The Compliance Demonstration activity will be performed for: Emission Unit: C- 00001 Emission Point: I0029 Process: CD1 Regulated Contaminant(s): CAS No: 007446-09-5 SULFUR DIOXIDE Item 210.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: As required by 6 NYCRR Part 212.4(a) sulfur dioxide (SO2) has been issued an environmental rating of B. The emission rate potential of sulfur dioxide from each emission source Air Po llution Control Permit Conditions Page 189 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 in this process shall remain less than 10 pounds per hour. Compliance testing shall be conducted upon request from the Department. Upper Permit Limit: 10. 0 pounds per hour Reference Test Method: EPA RM 6C Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 211: Compliance Demonstration Effective between the dates of 09/01/2002 and 09/01/2007 Applicable State Requirement: 6NYCRR 212.4(a) Item 211.1: The Compliance Demonstration activity will be performed for: Emission Unit: C- 00002 Process: CD2 Regulated Contaminant(s): CAS No: 007446-09-5 SULFUR DIOXIDE Item 211.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: As required by 6 NYCRR Part 212.4(a) sulfur dioxide (SO2) has been issued an environmental rating of B. The emission rate potential of sulfur dioxide from each emission source in this process shall remain less than 10 pounds per hour. Compliance testing shall be conducted upon request from the Department. Upper Permit Limit: 10. 0 pounds per hour Reference Test Method: EPA RM 6C Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: AVERAGING METHOD AS PER REFERENCE TEST METHOD INDICATED Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 212: Compliance Demonstration Effective between the dates of 09/01/2002 and 09/01/2007 Air Po llution Control Permit Conditions Page 190 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003
Applicable State Requirement: 6NYCRR 212.4(a) Item 212.1: The Compliance Demonstration activity will be performed for: Emission Unit: M- 00001 Regulated Contaminant(s): CAS No: 007782-50-5 CHLORINE Item 212.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: As required by 6 NYCRR Part 212.4(a) chlorine has been issued an environmental rating of B. The emission rate potential of chlorine from each emission source in this emission unit shall remain less than 10 pounds per hour. Compliance testing shall be conducted upon request from the Department. Upper Permit Limit: 10. 0 pounds per hour Reference Test Method: EPA RM 18 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: 1-HOUR AVERAGE Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY Condition 213: Compliance Demonstration Effective between the dates of 09/01/2002 and 09/01/2007 Applicable State Requirement: 6NYCRR 212.4(a) Item 213.1: The Compliance Demonstration activity will be performed for: Emission Unit: M- 00002 Regulated Contaminant(s): CAS No: 007782-50-5 CHLORINE Item 213.2: Compliance Demonstration shall include the following monitoring: Monitoring Type: INTERMITTENT EMISSION TESTING Monitoring Description: Air Po llution Control Permit Conditions Page 191 of 192 FINALPermit ID: 6-4058-00003/00365 Facilit y DEC ID: 6405800003 As required by 6 NYCRR Part 212.4(a) chlorine has been issued an environmental rating of B. The emission rate potential of chlorine from each emission source in this emission unit shall remain less than 10 pounds per hour. Compliance testing shall be conducted upon request from the Department. Upper Permit Limit: 10. 0 pounds per hour Reference Test Method: EPA RM 18 Monitoring Frequency: AS REQUIRED - SEE MONITORING DESCRIPTION Averaging Method: 1-HOUR AVERAGE Reporting Requirements: UPON REQUEST BY REGULATORY AGENCY

Air Po llution Control Permit Conditions Page 192 of 192 FINAL