Potline Start up, Shutdown and Malfunction Plan Page 1 of 8 Alcoa

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### Condition: Start

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

- up of a Potline served by this emission control system creates or leads to a situat ion 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 or re

- start is defined as the p rocess of re

- energizing an idled section(s) of aluminum reduction cells that is serviced by a common emission control device. The start

- up begins when the first idled reduction cell is energized. The start

- up concludes no more than 180 days following star t

- up. Appropriate 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 Potline that the emission control system is on line and operating within normal parametric limits.

2

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

3

. 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 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.Potline Start up, Shutdown and Malfunction Plan Page 2 of 8 Alcoa

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### Condi tion: Shut

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

- down of Potlines served by this emission control system creates or leads to a situatio n 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 int entional shut down of the Potline for a period of an hour or longer. The shut

- down process includes the stoppage of power to the Potline. The shut

down begins when operations are intentionally shut down for a period of an hour or more. The shut

- down conc ludes when the components of the system have been secured in a shutdown mode or a startup is initiated. The scrubber shall run until the Potline shutdown has been secured. Appropriate limits for parametric ranges during a shut

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

1

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

- start the emission control system are to be initiated.

2

. The shut

- down concludes when the components of the system have been secured in a shutdown mode. The emission control system may be shut down after this has occurred.

3

. The Shut

- Down 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 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 iss ue.Potline Start up, 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 wi thin 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 Device or inlet duct, a direct lightning strike, a loss of electrical power, a hurricane, an

e arthquake, a tornado or a system fire that results in uncontrolled emissions.

1

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

2

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

3

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

4

. The system operator or proxy will be responsible for logging the time, date, duration and cause of the malfunction, extraordinary actions taken beyond the scope of this plan, and initials or a signature. Maintenance personn el 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 i nto the semi

- annual reporting period log kept by the Environmental Department.Potline Start up, 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 the normal operating range are visibly being emitted from the exhaust(s) of the emission c ontrol 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 emi ssions 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 including, 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

. Following 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, efficient, and timely manner.

4

. The system operator will be responsible for logging the tim e, 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 Environmenta l Department.Potline Start up, 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 wit hin 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) central monitoring system for more than one (1) h ours 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 feeder tph (tons per hour) parametric that is below established limits of 7.0 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 an d 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 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 malfun ction 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.Potline Start up, Shutdown and Malfunction Plan Page 6 of 8 Alcoa

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### Condition: Loss of Pa rametric Monitoring

– Fan Amperage Signal In the event of a loss of the fan amperage signal 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. E xamples of loss of signal include, but are not limited to; unexpected failure of the programmable logic controller (PLC) and Wonderware (Data logging) central monitoring system for more than one (1) hour in any twenty

- four (24) hour period. This also incl udes loss of a measurement device (signal) component that results in a daily cumulative fan amperage

- hour parametric that is below established limits of 425 amps each (for 4 fan operation) or 465 amps for 3 fan operation.

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 m ake 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.Potline Start up, 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 th is emission control system (less than 7.0 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 include, but are not limited t o; 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 air lift material transfer units, fre sh 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 operator is to confirm the system s tatus and/or problems with air float blowers, air lift 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. If only the feeder is faulted utilize the bypass to re

- establish feed until the feeder can be repaire d.

2

. Following this initial response, the operator or proxy is to notify appropriate 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 replaceme nt(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

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

- annual reporting period log kept by the Environmental Department.Potline Start up, 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 co ntrol system as indicated by a daily cumulative fan amperage

- hour parametric that is below established limits of 425 amps each (for 4 fan operation) or 465 amps (for 3 fan operation), the following malfunction and corrective action plan must be initiated w ithin 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 red uce 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 amperage set point on the main fan controller needs to be che cked to insure proper setting as well as the operating condition of the fan motor. Operator needs to insure that compartment (cells) differential pressures are within control. The operator is to log the time that the condition was first noticed or report ed 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 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 malfunctio n 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.