Startup, Shutdown and Malfunction Plan 

In Accordance with Brick and Structural Clay 

National Emission Standard for Hazardous Air Pollutants 

 For 

BORAL BRICKS 

AUGUSTA FACILITY 

PLANT 5 

AUGUSTA, GEORGIA 

LAST REVISED 

December 2008 

Responsible Official Signature 

________________________________________________________________________ 

Mike Kuvinka Regional Production Manager Date 
TABLE OF CONTENTS 

1.0 INTRODUCTION..............................................................................................................1 

2.0 PURPOSE ...........................................................................................................................2

3.0 REGULATORY ANALYSIS ............................................................................................3

4.0 AFFECTED SOURCES AND CONTROL DEVICES ..................................................5

5.0 PROCEDURES FOR STARTUP, SHUTDOWNS, & MALFUNCTIONS ..................6

5.1 Startup Procedures ...................................................................................................7 

5.2 Shutdown Procedures .............................................................................................10 

5.3 Malfunction Procedures .........................................................................................13 

LIST OF MALFUNCTIONS ..............................................................................15 

6.0 RESPONSIBILITIES AND POINTS OF CONTACT .................................................44

6.1 Organizational Chart ..............................................................................................44 

6.2 Recordkeeping Plan ...............................................................................................44 

6.3 Training Requirements...........................................................................................44 

6.4 SSMP Version Control Procedures ........................................................................44 

7.0 REPORTING REQUIREMENTS .................................................................................45

7.1 Overview of Requirements ....................................................................................45 

7.2 Example Report Form ............................................................................................47 

7.3 Addresses ...............................................................................................................47 

Appendix A – SSMP Reports 

 Incident Report Form 

 Incident/Malfunction Tracking Log 

 Startup Shutdown Log 

 Notification Report for Malfunctions not Covered by SSMP 

Appendix B – Semi Annual Reports 

Appendix C – Previous Versions of SSMP 
Revision to SSMP: 

Date of Revision Reason for Revision 

August 8, 2006 Original SMMP 

July 2, 2007 Plan revised/updated based on NOV from GA 

DEP (March 2007) 

November 2008 Revised Personnel 

November 2008 Modified Incident Reporting Log 

 
Startup, Shutdown and Malfunction Plan Boral Bricks 

Augusta Plant 5 

 Page 1 of 47 BORA-3_Augusta 5 SSMP.doc 

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SECTION 1.0- INTRODUCTION

This Startup, Shutdown, and Malfunction Plan (SSMP) has been developed to meet the 

requirements found in the National Emission Standard for Hazardous Air Pollutants (NESHAP) 

codified in 40 CFR Part 63, Subpart A {§63.6(e)} and Subpart JJJJJ {§63.8420(c)}. This SSMP 

covers the Plant 5 tunnel kiln (EU05), which is the affected source in the Subpart JJJJJ, and the 

Hellmich dry hydrated lime injection baghouse system (DIFF2). 

At all times, including periods of startup, shutdown, and malfunction, Boral Bricks Augusta 

Plant 5 (Boral Bricks) will operate and maintain any air pollution control equipment and 

monitoring equipment that is used to meet the standard in a manner consistent with safety and 

good air pollution control practices for minimizing emissions to the levels required by the 

relevant standards (i.e., meet the emission standard or comply with the SSMP). Determination of 

whether such operation and maintenance procedures are being used will be based on information 

that may include, but is not limited to, monitoring results, review of operation and maintenance 

procedures (e.g. the SSMP), review of operation and maintenance records, and inspection of the 

source. 

Malfunctions will be corrected as soon as practicable after their occurrence in accordance with 

this SSMP. To the extent that an unexpected event arises during a startup, shutdown, or 

malfunction, Boral Bricks will comply by minimizing emissions during such a startup, 

shutdown, and malfunction event consistent with safety and good air pollution control practices. 

The remainder of this document summarizes the procedures that will be followed during periods 

when the Plant 5 kiln and control device are being started, shutdown, and during malfunctions. 

Boral Bricks must record each start-up, shutdown, or malfunction period and document any 

additional information required by the regulation. Examples of forms that can be used for these 

instances have been included in this SSMP. 
Startup, Shutdown and Malfunction Plan Boral Bricks 

Augusta Plant 5 

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SECTION 2.0- PURPOSE

Under 40 CFR 63.6(e), Boral Bricks is required to develop and implement for the Plant 5 kiln 

and control device a written SSMP that describes, in detail: (1) procedures for operating and 

maintaining the source during periods of startup, shutdown, and malfunction; (2) a program of 

corrective action for malfunctioning process; and (3) the air pollution control and monitoring 

equipment used to comply with the relevant standard. The purpose of the SSMP is to: 

(A) Ensure that, at all times, Boral Bricks operates and maintains air pollution control and 

monitoring equipment in a manner consistent with safety and good air pollution control practices 

for minimizing emissions to the levels required by the relevant standards; 

(B) Ensure that Boral Bricks is prepared to correct malfunctions as soon as practicable after their 

occurrence in order to minimize excess emissions of hazardous air pollutants; and 

(C) Reduce the reporting burden associated with periods of startup, shutdown, and malfunction 

(including corrective action taken to restore malfunctioning process and air pollution control 

equipment to its normal or usual manner of operation).
Startup, Shutdown and Malfunction Plan Boral Bricks 

Augusta Plant 5 

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SECTION 3.0- REGULATORY ANALYSIS 

The general regulatory requirements cited below are addressed in this plan: 

 §§63.6(e)(3) of Subpart A, General Provisions and 63.8420(c) of Subpart JJJJJ requires 

that Boral Bricks develop and implement a SSMP for operations used to comply with the 

Brick and Structural Clay NESHAP. This SSMP is intended to meet the requirements for 

Boral Bricks Plant 5 kiln operations. 

 §63.6(e)(3) of Subpart A, General Provisions, requires Boral Bricks to describe the 

corrective action that will be taken if a malfunction occurs at an affected process, air 

pollution control device or monitoring equipment. 

 In addition to the requirements to develop and implement a written SSMP, Boral Bricks 

is also required under §63.6(e)(3)(vii) to perform the following activities or functions: 

– Keep records of any malfunction event that occurs and keep records of the actions 

taken to minimize emissions during the event. 

– Submit reports if procedures taken during the event are not consistent with the 

procedures that are included in the SSMP and excess emissions occurred. 

– Revise the SSMP if a malfunction occurs that has not been described within this 

SSMP or procedures for corrective action have not been adequately described. 

– Update the plan if requested by EPA or the appropriate State or Local Air 

Pollution Control Authority. 

3.1 Definition of “Malfunction” 

During the course of normal operations, Boral Bricks may experience malfunction events. 

Please be aware that facilities may use a different definition of the term “malfunction” than the 

regulatory definition. The General Provisions define a “malfunction” as: 

Any sudden, infrequent, and not reasonably preventable failure of air 

pollution control and monitoring equipment, process equipment, or a 

process to operate in a normal or usual manner which causes, or has the 

potential to cause, the emission limitations in an applicable standard to 

be exceeded. (§63.2). 

As stated above, a malfunction, as defined under Part 63, must have the potential to cause an 

exceedance in the emission limitations of the standard. This plan, however, is designed to 

document all upsets and to determine whether or not they meet the definition of a “malfunction” 

under the rule. 
Startup, Shutdown and Malfunction Plan Boral Bricks 

Augusta Plant 5 

 Page 4 of 47 BORA-3_Augusta 5 SSMP.doc 

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Boral Bricks also has a separate plan for routine maintenance of the Plant 5 kiln process 

equipment and control device covered under the Brick and Structural Clay NESHAP that is 

called our Operating, Monitoring, and Maintenance Plan (OMMP). According to our OMMP, 

routine maintenance operations must be performed in accordance with the equipment 

manufacturer’s specifications and recommendations, as well as the procedures specific to Boral 

Bricks that are detailed in our OMMP. 
Startup, Shutdown and Malfunction Plan Boral Bricks 

Augusta Plant 5 

 Page 5 of 47 BORA-3_Augusta 5 SSMP.doc 

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SECTION 4.0- AFFECTED SOURCES AND CONTROL DEVICES 

This plan covers the following devices: 

General Description: Plant 5 Tunnel Kiln Controlled by Dry Hydrated 

Lime Injection Baghouse 

Affected Source: Plant 5 Tunnel Kiln (EU05) 

Capture/Control/Monitoring Device ID: Dry Hydrated Lime Injection Baghouse System 

(DIFF 2) 

Brief Description of System: 

The Plant 5 tunnel kiln is a sawdust fired kiln designed to produce 21 tons of fired brick per 

hour. Boral’s Augusta Plant 3, 4, & 5 facility currently has four operating kilns. Due to the sitewide potential emissions of HF, HCl and total HAP, the Boral Bricks complex is a major source 

of HAP. 

The Plant 5 tunnel kiln was operating prior to the promulgation date of July 22, 2002, and thus 

the kiln must comply with the “existing source MACT requirements” that are contained in 40 

CFR Part 63, Subpart JJJJJ. The existing source MACT requirements require the kiln to meet 

the following limits: 

HF – 90% control or 0.057 lb/ton (0.029 kg/Mg) 

HCl – 30% control or 0.26 lb/ton (0.13 kg/Mg) 

PM – 0.42 lb/ton (0.21 kg/Mg) (Method 5 filterable PM) 

VE: No Visible Emissions per Method 22 

 

Boral Bricks Augusta Plant 5 elected to add a Hellmich dry injection baghouse system (DIFF) in 

order to comply with the above limits. 
Startup, Shutdown and Malfunction Plan Boral Bricks 

Augusta Plant 5 

 Page 6 of 47 BORA-3_Augusta 5 SSMP.doc 

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5.0 PROCEDURES FOR STARTUP, SHUTDOWNS, & MALFUNCTIONS 

This section includes a description of Boral Augusta Plant 5 standard procedures for starting Kiln 

3 (EU05), and reagent injection baghouse system, shutting down the kiln and reagent injection 

baghouse system, and for dealing with malfunctions that occur. For the purposes of this plan, the 

malfunctions include only those incidents that have the potential to cause an exceedance of the 

emission or operating limits. These situations would include: 

o A situation that causes the emissions from Kiln 3 (EU05) to bypass the control 

device (DIFF2) be vented directly to the atmosphere; and 

o A situation that causes the reagent injection baghouse system to fail, thus 

increasing emissions above the NESHAP limits. 

o An occurrence that causes the operating limits to be exceeded. 

o Failure of the electronic monitoring system. 

In general, the focus of our procedures is to protect both the integrity of the control system and 

reduce the emissions to the atmosphere. Boral believes that both are critical to ensuring the 

long-term emission reduction ability of the system. In addition, the safety of plant personnel and 

visitors is always the first priority. 

To balance these, Boral follows the following general principles: 

 The exhaust from the kiln is vented through the control device when the stack 

temperature is within the acceptable range. Venting at too low a temperature could cause 

moisture to enter the system and cause the lime to solidify. Venting at too high a 

temperature could damage the bags which would lead to visible and gaseous emissions. 

[It should be noted that Boral uses bags appropriate for the expected temperature ranges 

to be encountered]. 

 There must be a clear path though the system for the exhaust to be vented through the 

control. Exhausting when there is no clear path (e.g., dampers closed to all cleaning 

modules) would damage the control, creating potential safety issues and potentially 

damaging the integrity of the cleaning process. 

 The lime feed into the control is continuous, unless feeding additional lime could damage 

the system. For example, the lime flow would be halted if there is not sufficient flow 

since the lime needs sufficient air flow to keep the particles suspended and to avoid 

blockages. 

All of these principles were considered when the procedures were developed. 

This plan includes three procedure for start-up, a regular shutdown procedure, an emergency 

shutdown procedure (i.e., “hard shutdown”) and numerous malfunction scenarios. 
BORAL BRICKS 

Augusta Plant 5 

 Page 7 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

SECTION 5.1- STARTUP PROCEDURES 

This section describes the start-up procedures for the Keller-American kiln and the Hellmich 

DIFF. The kiln was first started in 1980 and has rarely been stopped. The Hellmich DIFF was 

brought online initially while the kiln was in operation (when the temperature of the flue gas is in 

the right temperature range). 

The standard start-up procedure for the kiln and control device is described on the following 

page. 

This same general procedure is followed for each start-up of the control/kiln. However, some 

steps are skipped if previously completed. 

In general, there are three possible start-up scenarios that could occur: 

 Cold kiln, cold control. As stated above, this scenario has yet to occur since the control 

was started while the kiln was “hot.” The procedure on the next page is based on a “cold 

kiln/cold control” start. 

 Hot kiln, cold control. The procedure on the next page was followed, except that the 

exhaust air was immediately “up to temperature.” (Initial System Start) 

 Hot kiln, hot control. This would be a re-start after some event caused the control to 

switch to bypass. Other than bypasses that occur for routine maintenance, an example of 

these events would be a brief power outage that causes the system dampers to close. In 

this event, the restart procedure would still run through the system checks, but most steps 

would be shortened since both the baghouse and the exhaust would be up to the correct 

temperature. 
BORAL BRICKS 

Augusta Plant 5 

 Page 8 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

The hot and cold startup procedures for the kiln and lime injection baghouse system are outlined 

below. Boral Bricks will document each time the system undergoes startup. 

Steps for Hot Startup Notes 

1. Reset the main gas valve and restart air 

compressor if necessary. 

2. Start signal is initiated from the kiln controls. 

3. The kiln exhaust fan at the DIFF starts in 

bypass mode and goes through a purge cycle 

of the kiln for safety. 

4. The burners are ignited and the DIFF 

switches immediately to the full automatic 

mode (full operation). The DIFF runs for one 

hour while checking to see that the exhaust 

temperature is above the minimum for proper 

operation. When the proper temperature is 

reached, the DIFF will be placed back into 

automatic operation and production will 

resume. 

System must be at a constant 

temperature of 284o

F before the DIFF 

can be started. 

In the event that the minimum 

temperature is not reached, the kiln 

will normally not be hot enough for 

the normal resumption of processing 

of brick. No new product will be 

introduced to the kiln and thus 

emissions will be minimized during 

this time. 

5. Heat kiln up until the temperature is 

sufficient to begin processing brick and start 

the pusher process. 

6. Check DIFF operation and insure that all 

controls are properly operating. 

 

STARTUP- NORMAL 
BORAL BRICKS 

Augusta Plant 5 

 Page 9 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Steps for Cold Startup Notes 

1. Reset the main gas valve and restart air 

compressor if necessary. 

2. Start signal is initiated from the kiln controls. 

3. The kiln exhaust fan at the DIFF starts in bypass 

mode and goes through a purge cycle of the kiln 

for safety. 

4. The burners are ignited. When the proper 

temperature is reached, the DIFF will be placed 

into automatic operation and production will 

commence. 

No new product will be introduced to the 

kiln until proper temperatures are 

reached and thus emissions will be 

minimized during this time. 

5. Heat kiln up until the temperature is sufficient 

to begin processing brick and start the pusher 

process. 

6. Check DIFF operation and insure that all 

controls are properly operating. 

Steps Taken to Minimize Emissions: 

1. When there is any type of malfunction of the kiln that results in the kiln 

stoppage such as interruption of natural gas supply or electrical power, 

no new product is placed into or comes out of the kiln. 

2. No new product is processed in the kiln until a proper operational 

temperature is reached for pushing new product into the kiln. The 

minimum temperature required for the DIFF operation will be reached 

before the kiln is at a proper temperature for introduction of new 

product. With no new product being introduced to the kiln, the level of 

emissions will be continually decreasing until the pushing of new 

production resumes. 

3. In order to minimize emissions, the fresh lime metering screw should be set to the 

maximum metering performance so that the baghouses fill with lime as quickly as 

possible. Once the reaction product cellular wheel sluice is removing material, you can 

assume that there is enough recirculated material in the process. The fresh lime meter 

can now be set to the normal flowrate setting (level established during the performance 

test). 
BORAL BRICKS 

Augusta Plant 5 

 Page 10 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

SECTION 5.2- SHUTDOWN PROCEDURES

There is generally minimal need for shutting down the control and/or the kiln. The kiln tends to 

remain in operation. If the control and/or the kiln need to be stopped, the following general 

principles impact the procedures 

 Unless a safety issue or control device integrity issue occurs, the kiln will continue to 

vent through the control device until the exhaust reaches the low temperature set point 

(284 oF). 

 Unless safety to Boral personnel and visitors or ongoing integrity of the control is 

threatened, all procedures will be aimed at minimizing avoidable emissions of HAP to the 

atmosphere. 

If the control must be taken offline for routine maintenance, the time will be documented as 

being part of the time allowed under the Routine Maintenance Bypass Allowance in Boral’s 

permit. 

5.2.1 Normal Shutdown Procedures 

The normal shutdown procedures for the kiln and lime injection baghouse system are listed 

below. Boral Bricks will document each time the system is shutdown. 

Steps for Kiln Shutdown Notes 

1. Initiate shutdown through the kiln controls. 

2. The burners are stopped at the kiln and the 

pushing of new product into the kiln is 

immediately stopped. 

Steps for DIFF Shutdown Notes 

1. Initiate shutdown through the kiln 

controls. 

2. The DIFF damper goes to the bypass 

position and the fan stops immediately. 

SHUTDOWN- NORMAL 
BORAL BRICKS 

Augusta Plant 5 

 Page 11 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

 

Steps for Long Term DIFF Shut Down Notes 

Following is the procedure for shutting 

the system down for a long period of time 

or if entrance inside the system is 

required. 

1. The fuel sources to the kiln will be 

stopped. Unless a safety issue or control 

device integrity issue occurs, the kiln will 

continue to vent through the control 

device until the exhaust reaches the low 

temperature set point (284 oF) 

2. When kiln exhaust temperature is 

below low temperature set point, the 

control will be placed in bypass mode. 

3. The filter bags will be cleaned to 

remove excess lime 

4. If the control is to sit for an extended 

period, the hoppers in the bottom of the 

baghouse will be emptied to the waste silo 

and the waste lime will be disposed. 

At this point the control can be shut down 

completely for maintenance. 

Steps Taken to Minimize Emissions: 

1. The introduction of new product into the kiln is stopped at the same time 

that the burners are stopped. 

2. The kiln will continue to vent through the control device until the exhaust reaches the 

low temperature set point (284 o

F). This insures that the exhaust will be cleaned as long 

as the raw gas may contain harmful emissions. 
BORAL BRICKS 

Augusta Plant 5 

 Page 12 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

5.2.2 Emergency Shutdown Procedures 

The emergency shutdown procedures for the kiln and reagent injection baghouse system are 

listed below. Boral Augusta Plant 5 will document each time there is an emergency shutdown. 

Emergency shutdown is triggered automatically by the system when it senses conditions that can 

lead to imminent danger or damage to equipment. Emergency stops buttons are also located in 

several areas of the plant. Emergency shutdown is exactly the same as is listed previously in 

section 5.2.1. 

Steps Taken to Minimize Emissions: 

 In an emergency shutdown, safety is the primary issue. Boral Augusta Plant 5 will work 

to minimize emissions to the extent practicable. 

 Maintenance will determine whether the shutdown was due to true malfunction of the 

system or due to a malfunction of a sensor. The kiln will be stopped if the shutdown is 

due to a baghouse malfunction that stops the exhaust fan or if the malfunction is a part of 

the kiln control system. If the emergency pertains to only the baghouse, only the 

baghouse will cease operation and the system will operate in bypass until the situation is 

controlled.

SHUTDOWN- EMERGENCY 
BORAL BRICKS 

Augusta Plant 5 

 Page 13 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

SECTION 5.3- MALFUNCTION PROCEDURES 

This section describes the overall approach to identifying the cause of a malfunction and 

correcting it. It should be noted that Boral-Augusta Plant 5 has a responsibility to assure worker 

safety and to comply with all NFPA safety requirements. This will often affect the approach that 

must be taken to rectify a malfunction situation. Boral-Augusta Plant 5 will work to minimize 

emissions at all times, while ensuring all other health and safety requirements are also met. 

Any malfunction of the baghouse initiates an alarm: 

Hellmich DIFF has 2 categories of alarms: 

1. WARNING ALARM: This is an audible alarm and a light will flash. The alarm devices are 

located both at the baghouse and inside the main plant facility to ensure that prompt attention 

can be given. There are a number of malfunctions that can trigger a fault within the system 

and trigger an alarm. Depending on the nature of the malfunction, the baghouse may or may 

not go to bypass immediately. Most of the faults begin as warnings of a minor malfunction 

that if not given attention will lead to a bypass of the system after a predetermined time 

period. The only malfunctions that lead to an immediate switch to bypass are loss of I.D. fan, 

loss of compressed air or loss of power. Too high or too low temperature to the baghouse 

will also lead to a bypass if they are not corrected. The graphic display will show the nature 

of the malfunction and indicate the part of the device that needs attention. 

2. CRITICAL ALARM: An alarm that is triggered by an event that puts personnel safety or 

equipment integrity in danger. A critical alarm will immediately cause the system to go into 

bypass and shutdown. This alarm is only triggered when either personnel are in danger or 

the integrity of the system could be compromised. Protecting the integrity of the system will 

ensure a more rapid return to normal operation of the control. In general, there is at least one 

system or indication alarm that would indicate problems before they would rise to the level 

of a critical alarm. 

Boral’s approach for minimizing emissions during any malfunctions are based on the following 

concepts: 

1. Minimize the amount of time the system is shut down. To minimize the amount of time the 

kilns and the DIFF systems are shutdown, Boral will: 

a. Respond as quickly as possible to each WARNING ALARM. 

b. Maintain spare parts on hand for all components that have or are known to have the 

potential for failure, as well as any parts recommended by the Kiln manufacturer and 

Reagent Injection Fabric Filter System manufacturer. 

MALFUNCTIONS- OVERVIEW 
BORAL BRICKS 

Augusta Plant 5 

 Page 14 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

c. Boral Augusta will maintain a trained employee on each shift that will be able to respond 

to the alarms, correct the malfunctions or have the ability to contact key staff to handle 

any malfunctions of the systems. 

2. Minimize the amount of emissions that are vented when the control device is not fully 

operational. To ensure that the amount of emissions that are vented to the atmosphere are 

minimized, Boral-Agugusta will:

a. In any instance where the kiln is operating under normal conditions but the reagent 

injection system is malfunctioning, Boral-Augusta will work as expeditious as possible to 

get the reagent injection fabric filter system either back on-line or operating under normal 

operating conditions. 

b. During any malfunction of the kiln, Boral-Augusta will work as expeditious as possible 

to get the kiln operating under normal conditions. As long as all reagent injection 

baghouse parameters are within normal operating ranges, the reagent injection baghouse 

will continue to be operated during any malfunction of the kiln. 

c. Boral-Augusta will either minimize the length of the control device downtime and 

bypass, or both, to the extent practicable during any malfunction. 

It is highly possible that there may be episodes that fit the malfunction listed in this SMMP, 

where the described malfunction may be occurring, but in reality all emission and operating 

limits are being met by the emission source. For instance, we may lose a motor on one of the 

baghouse discharge valves for a few hours, but due to constant addition of reagent, we are 

continually meeting all limits while the motor is being replaced. In any circumstance where it 

can be determined that the specific malfunction event as listed in this document is occurring, but 

has no potential for exceeding the NESHAP limits, Boral-Augusta will document each 

occurrence as a malfunction event, document the specifics of the event, but will not report it as a 

malfunction (see malfunction definition in §63.2 or in Section 3.0 of this document) when 

compliance can be documented for the occurrence. 

Boral will document each occurrence as a malfunction event and document the specifics of the 

event. 
BORAL BRICKS 

Augusta Plant 5 

 Page 15 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

For purposes of this plan, a list of the types of potential malfunctions that can occur, the primary 

alarm type, and the Malfunction Number assigned are presented below. Boral Bricks has 

generated standard procedures that will be followed when these malfunctions occur as well as 

any malfunctions due to Acts of God or power failures. 

PLANT 5 KILN MALFUNCTIONS 

MALFUNCTION 

NUMBER MALFUNCTION NAME Type of Alarm 

1 Kiln out of Balance (improper balance of 

air flow ) 

None – Visual observation 

2 Kiln Malfunction that causes a bypass of 

Lime Injection Baghouse System 

Visible and audible alarm if 

burners are out or high 

temperature alarm condition. 

LIME INJECTION FABRIC FILTER SYSTEM MALFUNCTIONS 

MALFUNCTION 

NUMBER MALFUNCTION NAME Type of Alarm 

1 No Reagent Feed - Failure of the silo 

reagent indicator level; Run out of 

reagent unknowingly (Indicator levels 

high. Or reorder, low) 

Warning Alarm 

Critical Alarm after 14 hours. 

2 No Lime Feed – Bridging of hydrated 

lime within the silo. 

Warning Alarm “Pod” has a low 

level alarm 

Critical Alarm after 14 hours 

3 Failure of fresh lime silo feed mechanism 

that feeds dosing screw 

Audible and visible alarm. 

4 Failure of fresh lime dosing screw Audible and visible alarm. 

5 Blockage at exit of fresh lime screw 

where lime is injected into the main duct. 

Audible and visible alarm. 

6 Failure of agitator screw Audible and visible alarm. 

7 Failure of rotary valve under the 

recirculation screw 

Audible and visible alarm. 

8 Failure of compressed air system Critical Alarm if the pressure 

drops below 60-65 PSI for more 

than 40 sec. 

9 Bag cleaning system failure Audible and visible alarm. 
BORAL BRICKS 

Augusta Plant 5 

 Page 16 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

10 Mechanical and Electrical Components – 

Failure of Motors, Fans, Valves, 

Bearings, Belts, etc. 

Audible and visible alarm. 

(Depending on extent of failure.) 

11 Ductwork Failure Visible alarm. 

12 Damper/ damper Drives failure Audible and visible alarm. 

13 Electrical Controls Failure Audible and visible alarm. 

(Depends on component failing.) 

14 Failure of the discharge rotary valve to 

the blower to the storage silo. 

Audible and visible alarm. 

15 Bag Failure- Manufacturers Defect, High 

Pressure Drop, Temperature, hole 

Observation 

16 Pressure drop across baghouse too high Audible alarm – Warning alarm at 

16 mbar. Critical alarm at 20 mbar 

17 Pressure drop across baghouse too low Visual observation. No alarm for 

low pressure drop. Audible alarm 

if bag cleaning is off. 

18 Visible emissions from stack None – visible inspection 

19 High temperature in baghouse Critical alarm if >500 oF 

20 Low temperature in baghouse Critical alarm if < 284 oF for 2 

hours 

21 Failure of Automatic Resets after a power 

outage 

 Acts of God 

 Loss of Power or Gas Audible and visible alarm. 

The general approach taken for each of these is presented in the remainder of this section. 
BORAL BRICKS 

Augusta Plant 5 

 Page 17 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: It is possible that the kiln can experience an out of balance 

malfunction. During such a malfunction, there would be an 

improper balance of air flows within the kiln. The kiln will 

continue to exhaust to the control device. However with 

improper balance of air flows, there could be an improper 

exhaust of kiln combustion zone pollutants that is backdrafted through the dryer and dryer stack. A malfunction 

of this system can provide an excessive amount of smoke 

Type of Malfunction: Kiln out of Balance

Possible Causes: Improper balance of airflow 

Type of Alarm: WARNING ALARM In most cases there will be no 

alarm. It will have to be discovered by observation. 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation and responds immediately. 

2. If there is an improper sensor indicator, the sensor will be corrected to ensure proper 

electronic feedback to the computer system. 

3. If the kiln is out of balance, the supervisor on call will be contacted immediately. 

4. Key Boral Bricks staff will identify the cause of the out of balance problem. 

5. If possible, the balance problem will be corrected while operating the kiln. 

6. If the balance problem cannot be corrected while operating the kiln, Boral Bricks will 

follow the shutdown procedure identified in this SSMP. 

Steps Taken to Minimize Emissions: 

1. Boral Bricks will continue to operate the control device as long as there is no inlet 

temperature variance that requires the DIFF to go to bypass to prevent damage. (Inlet 

temperature exceedances are addressed later in Kiln Malfunction 2 and DIFF 

Malfunction 20&21). 

2. For the exhaust sent to the control device, visible emissions can be created by an out of 

balance malfunction. Prompt steps will be taken to correct the improper balance. The 

continued operation of the control device will minimize all pollutant emissions. 

3. If there is visible back-drafting through the dryer, Boral Bricks will consider such 

occurrence a malfunction. Prompt steps will be taken to correct the improper balance. 

Boral Bricks will continue to operate the control device to minimize emissions from the 

kiln exhaust. 

4. If there are no visible emissions in accordance with Method 22 and no back-drafting to 

the dryer, the above occurrence will not be considered a malfunction as identified in 

§63.2 and will not be reported as such. 

KILNMALFUNCTION 1
BORAL BRICKS 

Augusta Plant 5 

 Page 18 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

 Description of Equipment: There may be occurrences that dictate for safety and good 

air pollution control practice reasons that the control device 

may be bypassed, as a result of a kiln malfunction, in order 

to protect equipment. 

Type of Malfunction: Kiln Malfunction that Causes a Bypass of Lime 

Injection Baghouse System

Possible Causes (not complete): Excessive Inlet Temperature 

Type of Alarm: WARNING ALARM Visible and audible alarms at the 

DIFF and inside the main production facility. 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. If there is an improper sensor indicator, the sensor will be corrected to ensure proper 

electronic feedback to the computer system. 

3. The plant manager will be contacted immediately. 

4. Key Boral Bricks staff will identify the cause of the operating problem. 

5. If possible, the operating problem will be corrected while operating the kiln. 

6. If the operating problem cannot be corrected while operating the kiln, Boral Bricks will 

follow the shutdown procedure identified in this SSMP. 

Steps Taken to Minimize Emissions: 

1. During a bypass of the control device, Boral Bricks will work to get the kiln back to 

normal operating conditions as soon as feasibly possible. The lime injection baghouse 

system will be diverted from bypass back to the control device as soon as the problem is 

corrected. 

KILN 

MALFUNCTION 2
BORAL BRICKS 

Augusta Plant 5 

 Page 19 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: The lime injection baghouse system requires free flowing 

lime. The system is equipped with a lime silo to provide 

this lime. There are sensors and level indicators within and 

below the silo to monitor free flowing lime. 

Type of Malfunction: No Lime Feed

Possible Causes (not complete): Failure of sensor monitoring free flowing lime; Failure of 

Level Indicator; Lime availability issue 

Type of Alarm: WARNING ALARM Audible and visible alarm at both 

the DIFF and in the main production facility. 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. Maintenance verifies that there either is or is not free flowing lime or that the sensor has 

failed and there is no fresh lime available. 

3. If there is free flowing lime, the lime flow sensor system and level indicator sensors will 

be analyzed and corrected to ensure proper feed to the computer system. 

4. If there is no free flowing reagent, maintenance will document either the mechanical 

problem (most likely one of the malfunctions listed as DIFF Malfunction 1 or 2) or the 

lack of reagent in the silo. 

5. If there is insufficient lime in the silo, the plant manager will be contacted immediately. 

6. Key Boral Bricks personnel will contact lime suppliers and will have lime expedited to 

the site. 

7. Lime will be fed into the system as soon as received in the lime storage silo. 

Steps Taken to Minimize Emissions: 

1. If there are only alarm, light, or sensor problems, these will be corrected to properly 

monitor the system. If the system is properly operating from a mechanical standpoint at 

or above the feeder setting with sufficient lime in the silo, the system is properly 

operating and is reducing emissions at or above the levels indicated in the performance 

test. There is no malfunction as defined in §63.2, and there are no additional steps to 

minimize emissions. 

2. If there is no lime in the silo, Boral Bricks will stop removing spent lime from the system 

until new lime is received and injection of new lime has commenced. During this time 

the control device will operate 100% on recycled lime. When new limestone is available, 

the feed and removal rate will be accelerated in a manner that restores the unit to the 

normal operating conditions as soon as possible. This method would likely be to attempt 

to feed the lime at approximately twice the normal rate for a period of time that would 

equal the time the unit operated without the fresh lime addition.

DIFF2 

MALFUNCTION 1
BORAL BRICKS 

Augusta Plant 5 

 Page 20 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: The lime injection baghouse system requires free flowing 

lime. The system is equipped with a lime silo to provide 

this lime. There are sensors and level indicators within and 

below the silo to monitor free flowing lime. 

Type of Malfunction: No Lime Feed

Possible Causes (not complete): Bridging of lime within the hopper over the feed 

mechanism. 

Type of Alarm: WARNING ALARM Audible and visible alarm - “Pod” 

has a low level alarm 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. Maintenance verifies that there either is or is not free flowing lime. 

3. If there is free flowing lime, the lime flow sensor system and level indicator sensors will 

be analyzed and corrected to ensure proper feed to the computer system. 

4. Through mechanical means or controls, the temporary bridging of the material will be 

eliminated. If the problem occurs with frequency, additional devices will be installed to 

eliminate the problem. These new devices would most likely have to be ordered and 

installed. More frequent attention to this potential problem by observation would be 

required during this time and a schedule would be assigned to the proper personnel to 

insure that lime flow was as continuous as possible in the interim. 

5. If there is insufficient lime in the silo, the plant manager will be contacted immediately. 

6. Key Boral Bricks personnel will contact lime suppliers and will have lime expedited to 

the site. 

7. Lime will be fed into the system as soon as received in the lime storage silo. 

Steps Taken to Minimize Emissions: 

1. If there are only alarm, light, or sensor problems, these will be corrected to properly 

monitor the system. If the system is properly operating from a mechanical standpoint at 

or above the feeder setting with sufficient lime in the silo, the system is properly 

operating and is reducing emissions at or above the levels indicated in the performance 

test. There is no malfunction as defined in §63.2, and there are no additional steps to 

minimize emissions. 

2. More frequent attention to this potential problem by observation would be required 

during this time and a schedule would be assigned to the proper personnel to insure that 

lime flow was as continuous as possible in the interim. 

3. The unit will continue to inject recycled material into the air stream during the 

malfunction time. 

DIFF2 

MALFUNCTION 2
BORAL BRICKS 

Augusta Plant 5 

 Page 21 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: On the bottom of the lime storage silo, there is a feed 

mechanism similar to an auger, which turns and discharges 

the lime to the bottom of the silo into the dosing screw. 

Type of Malfunction: Failure of fresh lime silo feed mechanism that feeds 

dosing screw 

Possible Causes (not complete): Feed mechanism failure 

Alarm Type: Audible and visible alarms at the DIFF and within the main 

production facility. 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. Maintenance verifies that there either is or is not free flowing lime. 

3. If there is a sensor failure, the sensor system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

4. If the feed mechanism is not operating, the plant manager will be contacted immediately. 

5. Key Boral Bricks personnel will identify the cause of the problem. 

6. If repairable by Boral Bricks staff, maintenance will work non-stop until the system is 

repaired. 

7. If non-repairable by Boral Bricks staff, the vendor or its representatives will be contacted 

to visit the site and make adequate repairs. 

8. Lime will be fed into the system as soon as repairs are completed. 

Steps Taken to Minimize Emissions: 

1. If there are only alarm, light, or sensor problems, these will be corrected to properly 

monitor the system. If the system is properly operating from a mechanical standpoint at 

or above the feeder setting with sufficient lime in the silo, the system is properly 

operating and is reducing emissions at or above the levels indicated in the performance 

test. There is no malfunction as defined in §63.2, and there are no additional steps to 

minimize emissions. 

2. If the feed mechanism is broken and not operable, Boral Bricks will stop removing spent 

lime from the system until the feed mechanism is repaired. During this time the control 

device will operate 100% on recycled lime. When the repair is completed, the feed and 

removal rate will be accelerated in a manner that restores the unit to the normal operating 

conditions as soon as possible. This method would likely be to attempt to feed the lime at 

approximately twice the normal rate for a period of time that would equal to the time the 

unit operated without the fresh lime addition. 

DIFF2 

MALFUNCTION 3
BORAL BRICKS 

Augusta Plant 5 

 Page 22 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: Fresh lime from the silo drops into the lime dosing screw 

(or auger). The fresh lime dosing screw feeds lime from 

the lime silo into the lime injection baghouse system. 

Type of Malfunction: Failure of fresh lime dosing screw (auger) 

Possible Causes (not complete): Motor failure; auger failure; electronics failure; bearing 

failure; electrical supply failure 

Alarm Type: Audible and visible alarms at the DIFF and within the main 

production facility. 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. Maintenance verifies that there either is or is not a problem with the dosing screw. 

3. If there is a sensor failure, the sensor system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

4. If the dosing screw is not operating, the plant manager will be contacted immediately. 

5. Key Boral Bricks personnel will identify the cause of the problem. 

6. If repairable by Boral Bricks staff, maintenance will work non-stop until the system is 

repaired. 

7. If non-repairable by Boral Bricks staff, the vendor or its representatives will be contacted 

to visit the site and make adequate repairs. 

8. Lime will be fed into the system as soon as repairs are completed. 

Steps Taken to Minimize Emissions: 

1. If there are only alarm, light, or sensor problems, these will be corrected to properly 

monitor the system. If the system is properly operating from a mechanical standpoint at 

or above the feeder setting with sufficient lime in the silo, the system is properly 

operating and is reducing emissions at or above the levels indicated in the performance 

test. There is no malfunction as defined in §63.2, and there are no additional steps to 

minimize emissions. 

2. If the dosing screw is not operable, Boral Bricks will stop removing spent lime from the 

system until the dosing screw is repaired. During this time the control device will operate 

100% on recycled lime. When the repair is completed, the feed and removal rate will be 

accelerated in a manner that restores the unit to the normal operating conditions as soon 

as possible. This method would likely be to attempt to feed the lime at approximately 

twice the normal rate for a period of time that would equal to the time the unit operated 

without the fresh lime addition. 

DIFF2 

MALFUNCTION 4
BORAL BRICKS 

Augusta Plant 5 

 Page 23 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: Fresh lime from the silo drops into the lime dosing screw 

(or auger). The fresh lime dosing screw feeds lime from 

the lime silo into the lime injection baghouse system. 

Type of Malfunction: Blockage at the exit of the fresh lime screw into the inlet 

duct. 

Possible Causes (not complete): Bridging of material, foreign materials, or sensor failure. 

Alarm Type: Audible and visible alarms at the DIFF and within the main 

production facility. 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. Maintenance verifies that there either is or is not a problem with the dosing screw. 

3. If there is a sensor failure, the sensor system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

4. The plant manager will be contacted immediately. 

5. Key Boral Bricks personnel will identify the cause of the problem. 

6. If repairable by Boral Bricks staff, maintenance will work non-stop until the system is 

repaired. 

7. If non-repairable by Boral Bricks staff, the vendor or its representatives will be contacted 

to visit the site and make adequate repairs. 

8. Lime will be fed into the system as soon as repairs are completed. 

Steps Taken to Minimize Emissions: 

1. If there are only alarm, light, or sensor problems, these will be corrected and the fresh 

lime screw will be restarted. If there is a blockage from bridging or from a foreign 

material, this will be cleared and the fresh feed system will be restarted. The recirculation 

of material will have continued during this time and the system is operating and is 

reducing emissions at or above the levels indicated in the performance test. There is no 

malfunction as defined in §63.2, and there are no additional steps to minimize emissions. 

2. If there is blockage at the exit of the dosing screw, Boral Bricks will stop removing spent 

lime from the system until the dosing screw is repaired. During this time the control 

device will operate 100% on recycled lime. When the repair is completed, the feed and 

removal rate will be accelerated in a manner that restores the unit to the normal operating 

conditions as soon as possible. This method would likely be to attempt to feed the lime at 

approximately twice the normal rate for a period of time that would equal to the time the 

unit operated without the fresh lime addition. 

DIFF2 

MALFUNCTION 5
BORAL BRICKS 

Augusta Plant 5 

 Page 24 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: Below the bag section of the lime injection baghouse 

system, used lime that is collected by the baghouse is 

dropped into a hopper. A screw keeps lime flowing to the 

rotary discharge valve. 

Type of Malfunction: Failure of agitator screw 

Possible Causes (not complete): Motor failure; auger failure; electronics failure; bearing 

failure; electrical supply failure 

Alarm Type: Audible and visible alarms at the DIFF and within the main 

production facility. 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) for either a high or low level alarm or possibly both at the same time and responds 

immediately. 

2. Maintenance verifies that there either is or is not a problem with the leveling auger. 

3. If there is a sensor failure, the sensor system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

4. If the leveling auger is not operating, the plant manager will be contacted immediately. 

5. Key Boral Bricks personnel will identify the cause of the problem. 

6. If repairable by Boral Bricks staff, maintenance will work non-stop until the system is 

repaired. 

7. If non-repairable by Boral Bricks staff, the vendor or its representatives will be contacted 

to visit the site and make adequate repairs. 

8. Lime will be fed into the system as soon as repairs are completed. 

Steps Taken to Minimize Emissions: 

1. If there are only alarm, light, or sensor problems, these will be corrected to properly 

monitor the system. If the system is properly operating from a mechanical standpoint at 

or above the feeder setting with sufficient lime in the silo, the system is properly 

operating and is reducing emissions at or above the levels indicated in the performance 

test. There is no malfunction as defined in §63.2, and there are no additional steps to 

minimize emissions. 

2. If the leveling auger is not operable due to a problem outside of the hopper, the unit can 

continue to operate using the existing filter cake on the bags to clean the exhaust stream 

until the auger is repaired. If work is required inside the hopper, the lime injection 

baghouse system will be shut down and placed into bypass until repairs are completed. 

During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction. 

DIFF2 

MALFUNCTION 6
BORAL BRICKS 

Augusta Plant 5 

 Page 25 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: A rotary air lock is located between the recirculating screw 

and the plenum that is bringing the exhaust from the kiln to 

the lime injection baghouse system. A failure of the rotary 

air lock would prevent recycling used lime into the 

incoming air stream. 

Type of Malfunction: Failure of rotary gate on recirculating screw (auger) 

Possible Causes (not complete): Motor failure; bearing/air lock failure; electronics failure 

Alarm Type: Audible and visible alarms at the DIFF and within the main 

production facility. 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. Maintenance verifies that there either is or is not a problem with the rotary gate. 

3. If there is a sensor failure, the sensor system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

4. If the rotary gate is not operating, the plant manager will be contacted immediately. 

5. Key Boral Bricks personnel will identify the cause of the problem. 

6. If repairable by Boral Bricks staff, maintenance will work non-stop until the system is 

repaired. 

7. If non-repairable by Boral Bricks staff, the vendor or its representatives will be contacted 

to visit the site and make adequate repairs. 

8. Used lime will be recycled through the system as soon as repairs are completed and 

normal operation of the baghouse will proceed. 

Steps Taken to Minimize Emissions: 

1. If there are only alarm, light, or sensor problems, these will be corrected to properly 

monitor the system. If the system is properly operating from a mechanical standpoint at 

or above the feeder setting with sufficient lime in the silo, the system is properly 

operating and is reducing emissions at or above the levels indicated in the performance 

test. There is no malfunction as defined in §63.2, and there are no additional steps to 

minimize emissions. 

2. If the rotary gate under the recirculating screw is not operable, fresh lime will continue to 

be injected and the unit operated in normal mode until the repairs are completed. The unit 

will only be placed in bypass if required for some portion of the repair procedure. 

3. During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction. 

DIFF2 

MALFUNCTION 7
BORAL BRICKS 

Augusta Plant 5 

 Page 26 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: The compressed air system, an integral part of the lime 

injection baghouse system, supplies compressed air for bag 

cleaning and for the bypass damper. 

Type of Malfunction: Failure of compressed air system 

Possible Causes (not complete): Mechanical or Electrical Failure 

Alarm Type: Audible and visible alarms at the DIFF and within the main 

production facility. 

 Critical Alarms if the pressure drops below 60-65 PSI 

for more than 40 seconds. 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. Maintenance verifies that there either is or is not a problem with the compressed air 

system. 

3. If there is a sensor failure, the sensor system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

4. If there is a mechanical failure such as a leak in the system or other mechanical failure, 

the plant manager will be contacted immediately. 

5. Key Boral Bricks personnel will identify the cause of the problem. 

6. If repairable by Boral Bricks staff, maintenance will work non-stop until the system is 

repaired. 

7. If non-repairable by Boral Bricks staff, the vendor or its representatives will be contacted 

to visit the site and make adequate repairs. 

Steps Taken to Minimize Emissions: 

1. If the malfunction is just an indicator light or sensor malfunction the light or sensor will 

be corrected as specified above. Since the system is properly operating from a 

mechanical standpoint, there is no malfunction as defined in §63.2 and there are no 

additional steps to minimize emissions. 

2. The air piping system allows Boral - Augusta to use more than one air compressor to 

furnish compressed air to the baghouse. In the event of a compressor failure, the 

baghouse will be switched to a backup compressed air source. 

3. The compressed air pressure has two set points. The LOW set point disables bag 

cleaning to preserve air for valve operations. When the LOW set point is reached, bag 

cleaning will be disabled and Boral - Augusta will continue to operate the baghouse until 

an undesirable pressure drop is achieved in the baghouse. Even though the pressure drop 

might increase, the control efficiency should not vary much if any at all. 

4. If the LOW-LOW set point is reached, the baghouse will be bypassed as air pressure is 

required to keep the baghouse outlet poppet valves open. 

5. If an undesirable pressure drop is met or exceeded, the baghouse system will go to bypass 

after a preset time until the compressed air system is corrected. During this phase of 

operation, the baghouse will be bypassed. 

DIFF2 

MALFUNCTION 8
BORAL BRICKS 

Augusta Plant 5 

 Page 27 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

6. During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction.
BORAL BRICKS 

Augusta Plant 5 

 Page 28 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: In order to operate at optimal control efficiency, the bags 

within the baghouse system must continuously and 

systematically be cleaned. 

Type of Malfunction: Bag Cleaning System Failure 

Possible Causes (not complete): Cage failures; seal failures; timing circuit failure 

Alarm Type: Audible and visible alarms at the DIFF and within the main 

production facility. 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. Maintenance verifies that there either is or is not a problem with the bag cleaning system. 

3. If there is a sensor failure, the sensor system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

4. If there is a bag cleaning system failure, the plant manager will be contacted 

immediately. 

5. Key Boral Bricks personnel will identify the cause of the problem. 

6. If repairable by Boral Bricks staff, maintenance will work non-stop until the system is 

repaired. 

7. If non-repairable by Boral Bricks staff, the vendor or its representatives will be contacted 

to visit the site and make adequate repairs. 

Steps Taken to Minimize Emissions: 

1. If the malfunction is just an indicator light or sensor malfunction the light or sensor will 

be corrected as specified above. Since the system is properly operating from a 

mechanical standpoint, there is no malfunction as defined in §63.2 and there are no 

additional steps to minimize emissions. 

2. If there is a failure of the bag cleaning system, Boral Bricks will attempt to fix the failure 

while continuing to operate the lime injection baghouse system as long as all other 

operating parameters are within desirable operating ranges. 

3. If the failure of the bag cleaning system cannot be corrected while operating the lime 

injection baghouse system, the lime injection baghouse system will go to bypass until the 

bag cleaning system failure is corrected. 

4. During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction. 

DIFF2 

MALFUNCTION 9
BORAL BRICKS 

Augusta Plant 5 

 Page 29 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: The lime injection baghouse system has a fan on the outlet 

side of the baghouse and has numerous valves, bearings, 

and other mechanical and electrical components. 

Type of Malfunction: Mechanical & Electrical Components - Failure of 

motors, fans, valves, bearings, belts, etc. 

Possible Causes (not complete): Motor, fan, valves, bearings, etc. component failures 

Alarm Type: Audible and visible alarms at the DIFF and within the main 

production facility. 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. Maintenance verifies that there either is or is not a problem with the mechanical and 

electrical components associated with the lime injection baghouse system. 

3. If there is a sensor failure, the sensor system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

4. If there are mechanical and electrical component failures, the plant manager will be 

contacted immediately. 

5. Key Boral Bricks personnel will identify the cause of the problem. 

6. If repairable by Boral Bricks staff, maintenance will work non-stop until the system is 

repaired. 

7. If non-repairable by Boral Bricks staff, the vendor or its representatives will be contacted 

to visit the site and make adequate repairs 

Steps Taken to Minimize Emissions: 

1. If the malfunction is just an indicator light or sensor malfunction the light or sensor will 

be corrected as specified above. Since the system is properly operating from a 

mechanical standpoint, there is no malfunction as defined in §63.2 and there are no 

additional steps to minimize emissions. 

2. If there is a failure of the mechanical and electrical components, Boral Bricks will 

attempt to fix the failure while continuing to operate the lime injection baghouse system 

as long as all other operating parameters are within desirable operating ranges. 

3. Some of the failures listed in this malfunction cannot be corrected while operating the 

lime injection baghouse system. If a mechanical and electrical component failure cannot 

be corrected while operating the lime injection baghouse system, the lime injection 

baghouse system will be shutdown until the failure is corrected. 

4. During this phase of operation, the baghouse will be bypassed. During any bypass or 

control device shutdown, the kiln will be operated as smoothly as possible to minimize 

emissions during the malfunction. 

DIFF2 

MALFUNCTION 10
BORAL BRICKS 

Augusta Plant 5 

 Page 30 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: The lime injection baghouse system has inlet ductwork 

from the kiln, outlet ductwork to the stack exit, and 

associated ductwork for bypass and control device gas 

recirculating during bypass or down time. 

Type of Malfunction: Ductwork Failure 

Possible Causes (not complete): Excessive temperature from kiln; unexpected abrasion; 

hidden damage under the insulation; etc. 

Alarm Type: Visible observation 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. Maintenance verifies that there either is or is not a problem with the ductwork. 

3. If there is a sensor failure, the sensor system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

4. If there are ductwork failures, the plant manager will be contacted immediately. 

5. Key Boral Bricks personnel will identify the cause of the problem. 

6. If repairable by Boral Bricks staff, maintenance will work non-stop until the system is 

repaired. 

7. If non-repairable by Boral Bricks staff, the vendor or its representatives will be contacted 

to visit the site and make adequate repairs. 

Steps Taken to Minimize Emissions: 

1. If the malfunction is just an indicator light or sensor malfunction the light or sensor will 

be corrected as specified above. Since the system is properly operating from a 

mechanical standpoint, there is no malfunction as defined in §63.2 and there are no 

additional steps to minimize emissions. 

2. If there is ductwork failure, Boral Bricks will attempt to fix the failure while continuing 

to operate the lime injection baghouse system as long as all other operating parameters 

are within desirable operating ranges. 

3. If the failure of the ductwork cannot be corrected while operating the lime injection 

baghouse system, the lime injection baghouse system will be shutdown until the 

ductwork failure is corrected. During this phase of operation, the baghouse will be 

bypassed. 

4. During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction. 

DIFF2 

MALFUNCTION 11
BORAL BRICKS 

Augusta Plant 5 

 Page 31 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: The lime injection baghouse system has several dampers 

located between the kin and the baghouse filter section for 

adding ambient air to temper the inlet temperature coming 

from the kiln. 

Type of Malfunction: Damper/Damper Drives Failure 

Possible Causes (not complete): Motor failure; damper failure; electronics failure 

Alarm Type: Audible and visible alarms at the DIFF and within the main 

production facility 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. Maintenance verifies that there either is or is not a problem with the damper. 

3. If there is a sensor failure, the sensor system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

4. If there is a damper component failure, the plant manager will be contacted 

immediately. 

5. Key Boral Bricks personnel will identify the cause of the problem. 

6. If repairable by Boral Bricks staff, maintenance will work non-stop until the system is 

repaired. 

7. If non-repairable by Boral Bricks staff, the vendor or its representatives will be contacted 

to visit the site and make adequate repairs. 

 

Steps Taken to Minimize Emissions: 

1. If the malfunction is just an indicator light or sensor malfunction the light or sensor will 

be corrected as specified above. Since the system is properly operating from a 

mechanical standpoint, there is no malfunction as defined in §63.2 and there are no 

additional steps to minimize emissions. 

2. If there is damper failure, Boral Bricks will attempt to fix the failure while continuing to 

operate the lime injection baghouse system as long as all other operating parameters are 

within desirable operating ranges. 

3. If the damper failure cannot be corrected while operating the lime injection baghouse 

system, the lime injection baghouse system will be shutdown until the damper is 

corrected. During this phase of operation, the baghouse will be bypassed. 

4. During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction. 

 

 

DIFF2 

MALFUNCTION 12
BORAL BRICKS 

Augusta Plant 5 

 Page 32 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: The reagent injection baghouse system has numerous 

electrical controls that are required to operate and monitor 

all operations associated with the system. Many of these 

systems may have been covered in previous sections, but 

this has been added as a “catch-all” malfunction for any 

outliers. 

Type of Malfunction: Electrical Controls Failure 

Possible Causes (not complete): Motors; fans; sensors; indicators; etc. 

Alarm Type: Audible and visible alarms at the DIFF and within the main 

production facility 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. Maintenance verifies that there either is or is not a problem with any electrical control. 

3. If there is a sensor failure, the sensor system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

4. If there is a electrical control failure, the plant manager will be contacted immediately. 

5. Key Boral Bricks personnel will identify the cause of the problem. 

6. If repairable by Boral Bricks staff, maintenance will work non-stop until the system is 

repaired. 

7. If non-repairable by Boral Bricks staff, the vendor or its representatives will be contacted 

to visit the site and make adequate repairs. 

Steps Taken to Minimize Emissions: 

1. If there is an electrical component failure, Boral Bricks will attempt to fix the failure 

while continuing to operate the lime injection baghouse system as long as there is power 

to key operating components of the lime injection baghouse and all other operating 

parameters are within desirable operating ranges. 

2. If the electrical component failure cannot be corrected while operating the lime injection 

baghouse system, the lime injection baghouse system will be shutdown until the damper 

is corrected. During this phase of operation, the baghouse will be bypassed. 

3. During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction. 

4. If the malfunction is just an indicator light or sensor malfunction the light or sensor will 

be corrected as specified above. All sensor or indicator malfunction that affect 

compliance status will be recorded under this Malfunction No. 14. 

 

DIFF2 

MALFUNCTION 13
BORAL BRICKS 

Augusta Plant 5 

 Page 33 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: A rotary valve discharges used reagent from the bagfilter 

hopper and pneumatically conveys it to a storage silo using 

a blower. 

Type of Malfunction: Discharge rotary valve failure 

Possible Causes (not complete): Motor failure; bearing/air lock failure; electronics failure; 

blower failure. 

Alarm Type: Audible and visible alarms at the baghouse and within the 

main production facility 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by an indicator light or 

alarm) and responds immediately. 

2. Maintenance verifies that there either is or is not a valve or valve component failure. 

3. If there is a sensor failure, the sensor system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

4. If there is a valve failure, the plant manager will be contacted immediately. 

5. Key Boral - Augusta personnel will identify the cause of the problem. 

6. Maintenance will immediately repair the valve or order parts or replacement as quickly as 

possible. 

Steps Taken to Minimize Emissions: 

1. If the malfunction is just an indicator light or sensor malfunction the light or sensor will 

be corrected as specified above. Since the system is properly operating from a 

mechanical standpoint, there is no malfunction as defined in §63.2 and there are no 

additional steps to minimize emissions. 

2. If the discharge valve is not operable, reagent will be continuously injected and the 

baghouse will alarm as usual. If the hopper fills and the valve is not repaired, reagent 

injection and bag cleaning will stop until the valve is fixed. As a last resort, the baghouse 

will be shut down and bypassed to repair the valve. 

3. During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction. 

 

 

DIFF2 

MALFUNCTION 14
BORAL BRICKS 

Augusta Plant 5 

 Page 34 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: The bags within the reagent injection baghouse system will 

periodically fail due to unforeseen reasons. 

Type of Malfunction: Bag Failure 

Possible Causes (not complete): Manufacturers defect; high pressure drop, temperature 

Alarm Type: None. Detected by visual observation. 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation (or alerted by a change in operating 

parameters) and responds immediately. 

2. Maintenance verifies that there either is or is not a bag failure. 

3. If there is a sensor failure, the sensor system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

4. If there is a bag failure, the plant manager will be contacted immediately. 

5. Key Boral - Augusta personnel will identify the cause of the problem. 

6. Maintenance will immediately replace the damage bags. 

Steps Taken to Minimize Emissions: 

1. If the malfunction is just an indicator light or sensor malfunction the light or sensor will 

be corrected as specified above. Since the system is properly operating from a 

mechanical standpoint, there is no malfunction as defined in §63.2 and there are no 

additional steps to minimize emissions. 

2. If there is bag failure, Boral - Augusta will attempt to fix the failure by isolating the 

modules and doing a bag inspection from the top plenums one at a time. When the bad 

bag is found by inspection, it will be replaced with a spare bag (on hand) and the plenum 

will be closed and the unit restarted immediately. If this does not take care of the problem 

or if many bags appear to need replacement, the baghouse will be bypassed and a 

contractor will be called in to assist in the replacement of the whole set of bags as quickly 

as possible. 

3. During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction. 

DIFF2 

MALFUNCTION 15
BORAL BRICKS 

Augusta Plant 5 

 Page 35 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: There is a pressure indicator to measure PD at the inlet and 

outlet of the baghouse. 

Type of Malfunction: Pressure Drop Higher Than Acceptable Range 

Possible Causes: Inefficient cleaning cycle in baghouse (e.g., timing or 

insufficient compressed air); faulty pressure indicator, reentrainment of reagent low fan motor amperage 

Type of Alarm: Audible and visible alarms at the baghouse and within the 

 main production facility 

Steps Taken to Correct Problem: 

1. Check all indicators to see if root cause can be determined. 

2. Determine if exhaust can still safely vent through one or more baghouse modules. If so, 

continue to vent through baghouse. If not, switch to bypass mode. 

3. Depending on root cause, follow remedy steps listed below. 

CAUSE REMEDY 

Incorrect Pressure Reading Clean Pressure Taps 

Check hoses for leaks 

Check diaphragm in gauge 

Bag cleaning not adjusted properly Increase cleaning frequency 

Increase compressed air pressure 

Insufficient compressed air pressure Increase pressure 

Check dryer and clean if necessary 

Check piping for closed valves or 

other obstructions 

Pulse valves failed Check diaphragms 

Check solenoids 

Check PLC/pulse panels 

Cleaning timer failure Check to see if timer is indexing all 

contacts 

Check output on all terminals 

Dust not being removed from bags Increase air pressure 

Condensation on bags 

DIFF2 

MALFUNCTION 16
BORAL BRICKS 

Augusta Plant 5 

 Page 36 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Excessive re-entrainment of dust Check hopper for plugging 

Continuously empty hopper 

Clean rows of bags randomly 

4. If malfunction cannot be repaired in 2 hours, notify management to evaluate whether 

change in kiln operation is warranted. 

5. Once the malfunctioning equipment has been repaired, follow start-up procedures. 

Steps Taken to Minimize Emissions: 

 Since high pressure drop most likely indicates excessive reagent on the bags, exhaust will 

continue to flow through the system unless it will cause a danger to personnel or the 

equipment. This will ensure that the maximum possible emission reduction is still 

achieved during the incident. 

 Boral - Augusta will maintain spare parts recommended by the baghouse vendor to 

ensure parts most likely to require replacement are available. 

 If there is an excessive pressure drop that can damage the baghouse, Boral - Augusta will 

bypass the system until the pressure drop issue is resolved and the baghouse can operate 

under normal operating conditions. 

 During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during malfunction. 
BORAL BRICKS 

Augusta Plant 5 

 Page 37 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: There is a pressure indicator measure PD at the inlet and 

outlet of the baghouse. 

Type of Malfunction: Pressure Drop Across Baghouse Lower Than 

Acceptable Range 

Possible Causes: Cleaning cycle too frequent; cleaning cycle based on time 

rather than pressure drop; power failure; exhaust Fan 

Failure 

Type of Alarm: Audible and visible alarms at the baghouse and within the 

main production facility 

Steps Taken to Correct Problem: 

1. Check all indicators to see if root cause can be determined. 

2. Determine if exhaust can still safely vent through one or more baghouse modules. If so, 

continue to vent through baghouse. If not, switch to bypass mode. 

3. If malfunction cannot be repaired in 2 hours, notify management to evaluate whether 

change in kiln operation is warranted. 

4. Once the incident has been repaired, follow start-up procedures, if the system was shut 

down. 

Steps Taken to Minimize Emissions: 

1. Increasing the reagent feed helps build the reagent cake up on the bags faster. The increase 

builds it up as soon as possible without causing other problems. 

2. If the exhaust has been minimized or is nil, there are little or no emissions. 

3. If there is an insufficient pressure drop that can damage the baghouse, Boral-Augusta will 

bypass the system until the pressure drop issue is resolved and the baghouse can operate 

under normal operating conditions. 

4. During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during malfunction. 

CE05 

MALFUNCTION 17
BORAL BRICKS 

Augusta Plant 5 

 Page 38 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: Visible emissions are observed from the DIFF 

Exhaust Stacks. 

Type of Malfunction: Visible Emissions from Stack 

Possible Causes: Bag breakage; improper duct balancing; improper seal at 

tube sheet; insufficient filter cake 

Type of Alarm: Visual observation. No alarm for low pressure drop. 

Audible alarm if bag cleaning is off. 

Steps Taken to Correct Problem: 

1. Check all monitors/indicators to see if root cause can be determined. 

2. To check for bag breakage, systematically close off one module at a time until location of 

leak can be determined. 

3. If bag breakage in one module is the cause, continue to vent through remaining, nonleaking modules. 

4. If the issue is other than bag breakage, determine if exhaust can still safely vent through 

one or more baghouse modules while work continues to fix the malfunctioning 

equipment. If so, continue to vent through baghouse. If not, switch to bypass mode. 

5. If malfunction cannot be repaired in 2 hours, notify management to evaluate whether 

change in kiln operation is warranted. 

6. Once the incident has been repaired, follow start-up procedures. 

Steps Taken to Minimize Emissions: 

1. Boral - Augusta will seek to identify whether a single baghouse module is causing the 

visible emissions (this would most often be the case) as soon as practicable. Then, the 

exhaust will be vented through the remaining modules. 

2. If the malfunction can only be fixed by shutting the baghouse down, Boral - Augusta will 

bypass the baghouse and will correct the problem 

3. During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction. 

DIFF2 

MALFUNCTION 18
BORAL BRICKS 

Augusta Plant 5 

 Page 39 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: There are thermocouples that measure the temperature of 

the incoming gas flow. 

Type of Malfunction: High Temperature in Baghouse 

Possible Causes: High kiln exhaust temperature 

High kiln exhaust flow 

Type of Alarm: Critical alarm if > 500 oF (“High-high temperature”) 

Steps Taken to Correct Problem: 

1. If critical alarm, DIFF will automatically switch to bypass to avoid damage to the DIFF. 

Check all indicators to see if root cause can be determined. 

2. If temperature remains below 500 o

F, continue to vent through one or more baghouse 

modules, unless there is a personnel safety or an additional control device integrity issue. 

3. Depending on root cause, follow remedy steps listed in the vendor operation and 

maintenance manual. 

4. If malfunction cannot be repaired in 2 hours, notify management to evaluate whether 

change in kiln operation is warranted. 

5. Once the incident has been repaired, follow start-up procedures. 

Steps Taken to Minimize Emissions: 

1. Boral - Augusta will respond to the indicator alarm as soon as practicable to help ensure 

that the Critical Alarm is not triggered. 

2. If there is an excessive temperature that can damage the baghouse, Boral - Augusta will 

bypass the system until the temperature issue is resolved and the baghouse can operate 

under normal operating conditions. 

3. During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during malfunction. 

 

DIFF2 

MALFUNCTION 19
BORAL BRICKS 

Augusta Plant 5 

 Page 40 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: There are thermocouples that measure the temperature 

 of the incoming gas flow. 

Type of Malfunction: Low Temperature in Baghouse 

Possible Causes: Cold air damper stuck open

Type of Alarm: Critical alarm if < 284° F for 2 hours 

Steps Taken to Correct Problem: 

1. Check all indicators to see if root cause can be determined. 

2. Verify that reagent is flowing to control device 

3. Determine if exhaust can still safely vent through one or more baghouse modules. If so, 

continue to vent through baghouse. If not, switch to bypass mode. 

4. Depending on root cause, follow remedy steps listed in the vendor operation and 

maintenance manual. 

5. If malfunction cannot be repaired in 2 hours, notify management to evaluate whether 

change in kiln operation is warranted. 

6. Once the incident has been repaired, follow start-up procedures. 

Steps Taken to Minimize Emissions: 

1. If the temperature is sufficient in any module, flow will continue through the control. 

2. If there is an insufficient temperature and can damage the baghouse, Boral - Augusta will 

bypass the system until the temperature issue is resolved and the baghouse can operate 

under normal operating conditions. 

3. During any bypass or control device shutdown, the kiln will be operated as smoothly as 

possible to minimize emissions during malfunction. 

DIFF2 

MALFUNCTION 20
BORAL BRICKS 

Augusta Plant 5 

 Page 41 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Description of Equipment: Failure of equipment to reset itself to correct operation after 

a power outage. 

Type of Malfunction: Failure of Automatic Resets following a power outage 

Possible Causes (not complete): Power failure 

Alarm Type: Observation by Boral - Augusta Staff 

Steps Taken to Correct Problem: 

1. Maintenance is contacted due to visual observation and responds immediately. 

2. Key Boral - Augusta personnel will identify the cause of the problem. 

3. Boral - Augusta staff and maintenance will work and trouble shoot the system until 

repaired. 

4. Upon resetting the equipment, the DIFF silo will be re-filled (if required) to normal levels 

with reagent. 

Steps Taken to Minimize Emissions: 

1. After a power failure, Boral - Augusta personnel will confirm that all default settings 

have been reset to the correct operating order as quickly as possible. 

2. In most cases, the DIFF will continue to operate and since there is reagent in the system 

during much of the malfunction HF will continue to be removed. 

DIFF2 

MALFUNCTION 21
BORAL BRICKS 

Augusta Plant 5 

 Page 42 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Type of Malfunction: Acts of God 

 

 

General Steps Taken to Correct Malfunction and Reduce Emissions

 Ensure that the situation has become stable and the hazards have been cleared before 

proceeding further. 

 Confirm the system status and note which equipment is off-line or otherwise impaired. 

 Notify appropriate maintenance or other responsible personnel (see Section 6.1). 

 Respond to correct or repair the malfunction in a safe, efficient and timely manner as 

soon as it is practicable, for example: 

o Right overturned equipment and attempt to reinstall/restart; and 

o Ensure all power and gas lines are functioning correctly and are free from defect 

 Suspend operations as soon as practicable until compliance can be assured if failure 

cannot be repaired in a timely manner. 

ACTS OF GOD
BORAL BRICKS 

Augusta Plant 5 

 Page 43 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

Type of Malfunction: Loss of Power or Gas 

 

General Steps Taken to Correct Malfunction and Reduce Emissions 

 Ensure that the situation has become stable and the hazards have been cleared before 

proceeding further. 

 Confirm the system status and note which equipment is off-line or otherwise impaired. 

 Notify appropriate maintenance or other responsible personnel. 

 Respond to correct or repair the malfunction in a safe, efficient and timely manner as 

soon as it is practicable, for example: 

 Call power company if power failure seems plant-wide; if not, trace power failure 

from equipment to power source; 

o Check source of gas; 

o Trace gas line from equipment to the source and determine whether any leaks 

or breaks in line exist; and 

o Repair any breaks or leaks that are found in the utility system at the facility. 

 A loss of gas pressure or a general loss of power will result in an automatic stoppage 

of the kiln operation and thus emissions will be minimized until power and or gas is 

restored to allow normal operations. If the power loss is only at the baghouse unit, 

there will be no exhaust from the kiln and the kiln will automatically stop and will not 

operate until the situation is corrected. 

LOSS OF POWER/GAS
BORAL BRICKS 

Augusta Plant 5 

 Page 44 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

 SECTION 6.0- RESPONSIBILITIES AND POINTS OF CONTACT 

SECTION 6.1- ORGANIZATIONAL CHART 

Table of key individuals (by name or position), their contact information (phone, pager, cell, 

email), their responsibilities, back up personnel. 

Plant Manager Emmitt McClellan 

Direct Phone: 706-823-8051 

Regional Production Manager Neal Ruth 

Direct Phone: 706-823-8047 

Corporate Environmental Manager: Frank Porter 

Cell Phone: 706-575-1359 

SECTION 6.2- RECORDKEEPING PLAN 

All data and reports demonstrating compliance with a MACT standard, as well as previous 

versions of the SSMP, must be maintained for five years. 

Location of Electronic File: All records will be kept at the plant premises for inspection on 

demand. 

SECTION 6.3- TRAINING REQUIREMENTS 

To be completed 

SECTION 6.4- SSMP VERSION CONTROL PROCEDURES 

Protocol for identifying when to update the plan, managing previous versions of the plan and 

document control procedures is included in Section 7.0. 
Boral Bricks, Inc. 

Augusta Plant 5 Plant 

 Page 45 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

SECTION 7.0- RECORDKEEPING AND REPORTING REQUIREMENTS 

SECTION 7.1- OVERVIEW OF REQUIREMENTS 

The type of records that will be retained by Boral-Augusta Plant 5 meet the requirements of Part 

63. These records include: 

 Log of all startups and shutdowns of the machines 

 Record of each malfunction, and whether the actions taken to correct the malfunction were 

the same as the SSMP. (It may be possible that some events are not malfunctions. If it can be 

determined that an event was not a malfunction, such an event will be documented). 

The types of reports that are required to be submitted by Boral-Augusta Plant 5 vary 

considerably, depending on whether the actions taken were consistent with the SSMP. 

 If the actions taken during the malfunction were consistent with this SSMP, Boral-Augusta 

Plant 5 will state this fact in our semiannual excess emissions report (due within 30 days 

following the end of each 6-month period) with the following information included 

(§63.10(d)(5)(i)): 

o Certifying signature of the owner/operator or other responsible official; 

o Statement that the actions taken during the malfunction were consistent with the 

Malfunction Plan; 

o The number, duration, and a brief description of malfunction that occurred during the 

reporting period (§63.10(d)(5)(i)) or a copy of a malfunction report form that 

includes this information (see Section 7.2.1 for an example form); 

o Whether any excess emissions and/or parameter monitoring exceedances are believed 

to have occurred during the malfunction (§63.10(d)(5)(ii)); and 

o Any additional information required by our State or permitting authority. 

 If the actions taken during a malfunction were not consistent with this SSMP, because the 

plan did not address the type of malfunction that occurred and/or the actions taken were not 

included in the current SSMP, and excess emissions occurred, the Environmental Supervisor 

should report the actions taken by telephone or facsimile (FAX) transmission within two (2) 

working days after the malfunction. A letter must then be sent within seven (7) working days 

after the malfunction. The letter should include the following information (§63.10(d)(5)(ii)): 

o Name, title, and certifying signature of responsible official; 

o Explanation of the circumstances of the malfunction; 

o The reasons for not following the current SSMP; and 

o Any additional information required by our State or permitting authority. 

 If actions taken during the malfunction were not consistent with the SSMP or did not address 

the particular type of malfunction that occurred, and the Boral-Augusta Plant 5’s SSMP 
Boral Bricks, Inc. 

Augusta Plant 5 Plant 

 Page 46 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

should include these events or actions for future events. Then General Provisions also 

require ((§63.6(e)(3)(viii)): 

o Revise the SSMP within 45 days after the malfunction to include procedures for 

operating and maintaining the source during similar malfunction events, with a 

program of corrective action to address the malfunctions; and 

o Report the revisions of your SSMP in the semi annual excess emissions report (within 

30 days following the end of each 6-month period). 
Boral Bricks, Inc. 

Augusta Plant 5 Plant 

 Page 47 of 47 BORA-3_Augusta 5 SSMP.doc 

 Revision 2- July 2, 2007 

SECTION 7.2- EXAMPLE REPORT FORMS 

i. Malfunction reports (internal) 

Forms to be completed for each malfunction that occurs - must include determination of whether 

SSMP was followed. 

ii. Malfunction Log 

Table listing each malfunction and whether it was included in plan or, if not, whether required 

notifications were provided

iii. Example Notifications 

Provide examples of: verbal/written notification required within 2 days of malfunction not 

included in SSMP; written notification required within 7 days of the end of a malfunction not 

included in SSMP; language to include in semiannual reports. 

iv. Addresses 

GEORGIA DEPARTMENT OF NATURAL RESOURCES 

Georgia Department of Natural Resources 

Environmental Protection Division 

Air Protection Branch 

4244 International Parkway, Suite 120 

Atlanta, Georgia 30354 

US Environmental Protection Agency 

EPA Region 4 Regional Office 

61 Forsyth Street 

Atlanta, GA 30303 
 

APPENDIX A – RECORDS OF SSM EVENTS 
Boral Bricks, Inc. 

Augusta Plant 5 Plant 

INCIDENT REPORT FORM 

 

MALFUNCTIONING DEVICE: 

DATE OF INCIDENT: ___________________________________ 

Explanation of Incident (include suspected cause- can reference Incident Code, if applicable) 

Duration : (Estimated)Start Time: 

 End Time: 

 Duration: 

Provide an estimate of excess emissions or a description parameter monitoring exceedances: 

1. Were all operating parameters (reagent feed setting, free flowing reagent 

and visible emissions (if applicable)) monitored during the incident? Y / N 

2. Were all parameters monitored to be within the permitted ranges during 

the incident? Y / N

If answers to 1 and 2 above are YES, this is not a malfunction, please sign below and stop. 

If either (or both) of the answers to 1 and 2 are NO, proceed with answering 3 and 4 below. 

3. Was this event included in the SSM plan? Y / N 

If YES, please list malfunction No. (i.e., DIFF-01) ____________________________ 

4. Were the procedures in SSM plan followed? Y / N

 If the answer to both questions 3 and 4 above is YES, sign below and stop. List 

malfunction in semi-annual report. See Section 7.1 of SSMP for information. 

 If either answer is NO, sign below and complete the remainder of the form. Immediate 

reporting required. See Section 7.1 of SSMP for information; see Sections 7.2.3 for 

example notifications. 

Signature: ___________________ Date: _________________________ 

If the answer to questions 3 and/or 4 above is NO, complete the following on Page 2: 

TRACKING 

NUMBER: ________ 
Boral Bricks, Inc. 

Augusta Plant 5 Plant 

INCIDENT REPORT FORM 

 

Action Taken to Correct the Problem: 

Actions Taken to Minimize Emissions During Problem: 

Measures Taken to Prevent a Reoccurrence of the Problem: 

Is this incident a malfunction under 40 CFR, Part 63? If not, why?: 

NOTE: SSM Plan must be revised to incorporate this malfunction (see Section 7.1) 
Boral Bricks, Inc. 

Augusta Plant 5 Plant 

Incident/Malfunction Tracking Log 

Date 

Tracking 

Number 

Was the 

Incident a 

Malfunction?

If YES, was 

the SMMP 

followed? 

If SSMP not followed.... 

W

Was 2nd day 

report called 

in or faxed? 

Was 7th day 

report mailed 

Was SSMP 

modified? 

1Add a reference letter to this column, if you need to add additional information below: 

abcd- 
BORAL BRICK

Augusta, GA 

START-UP AND SHUTDOWN LOG 

DATE 

Begin 

“Start-up” 

End 

“Start-up”

Begin 

“Shutdown”

End 

“Shutdown” Notes 

 
Boral Bricks, Inc. 

Augusta Plant 5 Plant 

NOTIFICATION REPORT FOR MALFUNCTIONS NOT COVERED BY SSMP

Type of Malfunction: 

Date of Malfunction: 

Explanation of the circumstances of the malfunction: 

Reasons for not following the current SSMP: 

Responsible Official: Name: 

Title: 

Signature 

Fax the above information within two (2) working days after the malfunction to: 

Georgia Department of Natural Resources 

Environmental Protection Division 

Air Protection Branch 

FAX: 404.363.7100 

Mail a letter with the above information within seven (7) working days after the malfunction to: 

Georgia Department of Natural Resources 

Environmental Protection Division 

Air Protection Branch 

4244 International Parkway, Suite 120 

Atlanta, Georgia 30354 

APPENDIX C – SEMI ANNUAL REPORTS 
APPENDIX C – PREVIOUS VERSIONS OF SSM PLAN