Anode Bake Oven Startup, Shutdown and Malfunction Plan Page 1 of 8 Alcoa

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### Condition: Start

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

- up of bake ovens served by this emission control system creates or leads to a s ituation that causes operation outside of appropriate parametric ranges for process gas flow or alumina flow, the following Start

- Up plan must be re

initiated within one hour of first becoming aware of the situation. A start

- up is defined as the process o f baking green anodes in a ring furnace using natural gas or propane as a fuel

. The start

- up begins when fuel and ignition are introduced to a furnace containing green anodes. The start

- up concludes when baked anode production begins. Appropriate limits for parametric ranges during a start

- up are those typical ranges that have previously been established for this emission control device.

1

. The Operator(s) is to assure that prior to start

- up of the furnaces that the emission control system is on line and o perating within normal parametric limits. The sonic tower low temperature setpoint should be reduced to ambient until the tower is conditioned (warmed up) by hot process gas. This prevents the system from shutting down on low temperature during attempted startups.

2

. When the emission control system is on

- line and operating within normal parametric limits, the Environmental Control Shift Technician will notify the Bake Oven Supervisor that the
start

- up of the furnaces can begin.

3

. In the event of operation ou tside of acceptable parametric limits, the Operator is to assure that the emission control system is still on line. If this is not the case, a shut down of the bake oven is to be initiated.

4

. The start

- up concludes when production of baked anodes begins.

5

. The Start

- Up is to be logged. Include the time, date, duration of event, extraordinary actions taken beyond the scope of this plan, and initials or a signature. Records of the start

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

- conformance with a n applicable requirement occur, it is to be entered into the semi

- annual reporting period log kept by the Environmental Department.

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

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### Condition: Shut

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

- down of bake ovens served by this emission control system creates or leads to a situation that causes operation outside of appropriate parametric ranges for process gas flow or alumina flow, the following Shut

- Down plan must be

re

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

A shut

- down is defined as the process of intentional shut down of the bake oven furnaces for a period of an hour or longer. The shut

- down begins when the flow of fuel to the furnaces is intentionally cut off. The shut

- down concludes when the components of the furnaces have been secured in a shutdown mode or a startup is initiated. Appropriate limits for parametric ranges during a shut

- down are those typical ranges that have previously been established for this emission control device.

1

. In the event of operation outside of approved parametric limits the Emissi on Control Shift Technician is to assure that the emission control system is still on line. If this is not the case, the shut down of bake oven is to proceed immediately and efforts to re

- start the emission control system are to be initiated immediately.

2

. The shutdown begins when the fuel to the furnace is intentionally cut off.

3

. The shut

- down concludes when the system components have been secured in a shutdown mode. This includes removal of the exhaust manifolds from the furnaces and removal of the end c overs of the furnaces side

- mains. Appropriate barricades must be in place around the open side mains.

4

. The Bake Oven supervisor will notify the Environmental Control Shift Technician that the furnaces have been secured . The Environmental Control Shift Te chnician will verify that the exhaust manifolds and side

- main end covers have been removed.

5

. Following verification that the exhaust manifolds and side

- main end covers have been removed, the emission control device will continue to operate for a minimum 1

- hour period to purge the side

- mains

6

. After the minimum 1

- hour purging, the emission control device can be shutdown.

7

. The Shut

- Down is to be logged. Include the time, date, duration of event, extraordinary actions taken beyond the scope of this plan, and i nitials or a signature. Records of the shut

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

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

- annual reporting period log kept by the Environmental Department.

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

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### Condition: Catastrophic Failure of Fume Control Equipment In the event of catastrophic failure of fume control equipment or components in this emission control system (device) the following malfunction and corrective action plan must be initiated within one hour of first becoming aware of a malfunction Examples of catastrophic failure include, but are not limited to; collapse of a Dry Injection Fume Control Devic e or inlet duct, a direct lightning strike, a loss of electrical power, a hurricane, an earthquake, a tornado or a system fire that results in uncontrolled emissions.

1

. As soon as the situation has become stable and hazards have been cleared, the operator o r proxy is to confirm the system status, noting which equipment on the unit is down or otherwise impaired. The operator is to log the time that the condition was first noticed or reported and also log the time at which he/she first began to respond to che ck the system
status.

2

. Following this initial response, the operator is to restart all operational equipment, notify appropriate maintenance (for necessary repairs), engineering and support personnel.

3

. Personnel responding to the malfunction are to make re pair(s), equipment replacement(s) or process change(s) to remedy the situation in a safe, efficient, and timely manner.

4

. The system operator or proxy will be responsible for logging the time, date, duration and cause of the malfunction, extraordinary actio ns taken beyond the scope of this plan, and initials or a signature. Maintenance personnel will be responsible for making appropriate entries into any maintenance logs.

5

. Records of the malfunction and maintenance activity are to be retained for five (5) y ears. Should non

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

- annual reporting period log kept by the Environmental Department.Anode Bake Oven Startup, Shutdown and Malfunction Plan Page 4 of 8 Alcoa

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### Condition: Visible Emissions

– Dusting Stack(s) In the event that emissions outside th e normal operating range are visibly being emitted from the exhaust(s) of the emission control system (device) the following malfunction and corrective action plan must be implemented within one hour of the initial observation of the malfunction. Examples of visible emissions or dusting stack(s) include, but are not limited to; continuous emissions observed by the operator (or reported to him) from the stack on the fume control system(s).

1

. The operator is to report the dusting stack(s) from any source inclu ding, but not limited to the daily visual checks made by the Operator. The operator is to log the time that the condition was first noticed or reported and also log the time at which he/she confirmed reported emissions or has initiated this plan.

2

. Followi ng this initial response, the operator is to initiate corrective action within one hour by having the appropriate compartment(s) shut down to make repairs.

3

. Personnel responding to the malfunction are to make repair(s) to remedy the situation in a safe, ef ficient, and timely manner.

4

. The system operator will be responsible for logging the time, date, duration and cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and initials or a signature in the visible emission log. If required, maintenance personnel will be responsible for making appropriate entries into any maintenance logs.

5

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

non

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

annual reporting period log kept by the Environmental Department.Anode Bake Oven Startup, Shutdown and Malfunction Plan Page 5 of 8 Alcoa

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### Condition: Loss of Parametric Monitoring

– Fresh Alumina Feeder Signal In the event of a loss of the fresh alumina feeder signal(s) for the emission control systems, the following malfunction and corrective action plan must be initiated within one hour of first becoming aware of a malfunction. Examples of loss of signal include, but are not limited to; unexpected failure of the programmable logic cont roller (PLC) and Wonderware (Data logging) central monitoring system for more than one (1) hours in any twenty

- four (24) hour period. This also includes loss of a measurement device (signal) component that results in a daily cumulative fresh alumina feede r tph (tons per hour) parametric that is below established limits of 0.5 tons per hour.

1

. The operator is to confirm the system status, noting if the Control room PLC is off line or if the Wonderware (data logging) central monitoring system is not recording data. The operator is to log the time that the condition was first noticed or reported and also log the time at which he/she first began to respond to check the system status.

2

. Following this initial response, the operator or proxy is to notify appropri ate maintenance personnel and/or contact outside contractor or restart the PLC or Wonderware system.

3

. Personnel responding to the malfunction are to make repair(s), equipment replacement(s) or process change(s) to remedy the situation in a safe, efficient, and timely manner.

4

. The system operator or proxy will be responsible for logging the time, date, duration and cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and initials or a signature. Maintenance personnel will be responsible for making appropriate entries into any maintenance logs.

5

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

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

sem i

- annual reporting period log, kept by the Environmental Department.Anode Bake Oven Startup, Shutdown and Malfunction Plan Page 6 of 8 Alcoa

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### Condition: Loss of Parametric Monitoring

– Static Pressure Signal In the event of a loss of the static pressure signal for the emission control systems, the following malfunction and c orrective action plan must be initiated within one hour of first becoming aware of a malfunction. Examples of loss of signal include, but are not limited to; unexpected failure of the programmable logic controller (PLC) and Wonderware (Data logging) centr al monitoring system for more than one (1) hour in any twenty

- four (24) hour period. This also includes loss of a measurement device (signal) component that results in a daily cumulative static pressure parametric that is below established limits.

1

. The operator is to confirm the system status, noting if the Control room PLC is off line or if the Wonderware (data logging) central monitoring system is not recording data. The operator is to log the time that the condition was first noticed or reported and also log the time at which he/she first began to respond to check the system status.

2

. Following this initial response, the operator or proxy is to notify appropriate maintenance personnel and/or restart the PLC or Wonderware system.

3

. Personnel responding to the malfunction are to make repair(s), equipment replacement(s) or process change(s) to remedy the situation in a safe, efficient, and timely manner.

4

. The system operator or proxy will be responsible for logging the time, date, duration and cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and initials or a signature. Maintenance personnel will be responsible for making appropriate entries into any maintenance logs.

5

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

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

- annual reporting period log, kept by the Environmental Department.Anode Bake Oven Startup, Shutdown and Malfunction Plan Page 7 of 8 Alcoa

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### Condition: Low Flow of Alumina In the event of low flow of alumina through this emission control system (less than 0.5 tons per hour) the following malfunction and corrective action plan must be initiated within one hour of first becoming aware of a malfunction. Examples of low alumina flow conditions in clude, but are not limited to; unexpected failure of the primary air gravity conveyor (air slide) or one of its components, (such as the media cloth membrane or the primary, air float, blowers), excessive downtime and /or failure (malfunction) of Dense pha se material transfer units, fresh alumina storage tank low (or empty) levels and excessive (or full) reacted alumina storage tanks. Also included are reductions in alumina flow due to excessive compartments out of service due to various reasons.

1

. The oper ator is to confirm the system status and/or problems with air float blowers, material transfer (removal) systems as well as confirm levels in the fresh and reacted storage tanks. The operator is to then log the time that the condition was first noticed or reported and also log the time at which he/she first began to respond to check the system status and notify proper appropriate personnel to initiate repairs and/or conditions.

2

. Following this initial response, the operator or proxy is to notify appropriat e maintenance personnel and/or initiate a maintenance work order, or restart the unit(s).

3

. Personnel responding to the malfunction are to make repair(s), equipment replacement(s) or process change(s) to remedy the situation in a safe, efficient, and timely manner.

4

. The system operator or proxy will be responsible for logging the time, date, duration and cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and initials or a signature. Maintenance personnel will be responsible for making appropriate entries into any maintenance logs.

5

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

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

- annual re porting period log kept by the Environmental Department.Anode Bake Oven Startup, Shutdown and Malfunction Plan Page 8 of 8 Alcoa

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### Condition: Low Flow of Process Gas In the event of low flow of process gas (low air flow) through this emission control system as indicated by a common static pressure of less than 8.0"w.g., the f ollowing malfunction and corrective action plan must be initiated within one hour of first becoming aware of a malfunction. Examples of low flow conditions include, but are not limited to; a failure or malfunction of a fan, an unexpected loss of electrical power and/or problems with multiple compartment downtime which reduce the static pressure parametric value below established limits.

1

. The operator is to confirm the system status, noting if compartments (cells) are either off line or otherwise impaired. The static pressure set point on the main fan controller needs to be checked to insure proper setting. Operator needs to insure that all fans are operating properly and that compartment (cells) differential pressures are within control. The operator is to log the time that the condition was first noticed or reported and also log the time at which he/she first began to respond to check the system status.

2

. Following this initial response, the operator or proxy is to notify appropriate maintenance
personne l and/or initiate a maintenance work order, or restart the unit(s).

3

. Personnel responding to the malfunction are to make repair(s), equipment replacement(s) or process change(s) to remedy the situation in a safe, efficient, and timely manner.

4

. The system operator or proxy will be responsible for logging the time, date, duration and cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and initials or a signature. Maintenance personnel will be responsible for making appropria te entries into any maintenance logs.

5

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

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

- annual reporting period log ke pt by the Environmental Department.