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 DateTABLE OF CONTENTS

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

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

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

4.0 AFFECTED SOURCES AN D 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 SSMPRevision 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 LogStartup, Shutdown and Malfunction Plan Boral Bricks Augusta Plant 5

Page 1 of 47 BORA-3_Augusta 5 SSMP.doc Revision 2- July 2, 2007 

### SECTION 1.0- INTRODUCTION

This Startup, Shutdown, and Malfunction Plan (SSMP) has been deve loped to meet the requirements found in the National Emission St andard 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 main tain any air pollution control equipment and monitoring equipment that is used to meet the st andard in a manner consistent with safety and good air pollution control practices for minimizi ng emissions to the le vels 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, monitori ng results, review of operation and maintenance procedures (e.g. the SSMP), review of operation a nd maintenance records, and inspection of the

source.

Malfunctions will be corrected as soon as practicab le 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 mi nimizing emissions during such a startup, shutdown, and malfunction event consistent with safety and good air pollu tion 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, a nd during malfunctions. Boral Bricks must record each start-up, shut down, or malfunction period and document any additional information required by th e regulation. Examples of forms that can be used for these

instances have been in cluded in this SSMP.Startup, Shutdown and Malfunction Plan Boral Bricks Augusta Plant 5

Page 2 of 47 BORA-3_Augusta 5 SSMP.doc Revision 2- July 2, 2007 

### SECTION 2.0- PURPOSE

Under 40 CFR 63.6(e), Boral Bricks is required to develop and im plement for the Plant 5 kiln and control device a written SSMP that describes, in detail: (1) proce dures for operating and maintaining the source during periods of startu p, shutdown, and malfunction; (2) a program of corrective action for malfunctioning process; a nd (3) the air pollution c ontrol and monitoring equipment used to comply with the releva nt standard. The purpose of the SSMP is to:

(A) Ensure that, at all times, Boral Bricks operates and maintains ai r 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 emi ssions of hazardous air pollutants; and

(C) Reduce the reporting burden associated with periods of startup, shutdown, and malfunction (including corrective action take n 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

Page 3 of 47 BORA-3_Augusta 5 SSMP.doc Revision 2- July 2, 2007 

### SECTION 3.0- REGULATORY ANALYSIS

The general regulatory requirements cite d below are addressed in this plan:

 §§63.6(e)(3) of Subpart A, General Provisi ons 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 SSM P is intended to meet the requirements for Boral Bricks Plant 5 kiln operations.

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

corrective action that will be taken if a malf unction 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 followi ng 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 th at 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 Pr ovisions define a “malfunction” as:

Any sudden, infrequent, and not reas onably 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 limitati ons in an applicable standard to be exceeded. (§63.2).

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

exceedance in the emission limitations of the st andard. 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 Revision 2- July 2, 2007 Boral Bricks also has a separate plan for ro utine maintenance of the Plant 5 kiln process equipment and control device covered under the Br ick and Structural Clay NESHAP that is called our Operating, Monitoring, and Maintena nce Plan (OMMP). According to our OMMP, routine maintenance operations must be pe rformed in accordance with the equipment manufacturer’s specifica tions 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 Revision 2- July 2, 2007 SECTION 4.0- AFFECTED SOU RCES AND CONTROL DEVICES

This plan covers the following devices:

General Description: Plant 5 Tunnel Kiln Controlled by Dry Hydrated Lime Injection Baghouse

Affected Source: Pl ant 5 Tunnel Kiln (EU05)

Capture/Control/Monitoring De vice 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 Plan t 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 He llmich dry injection bag house 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 Revision 2- July 2, 2007 5.0 PROCEDURES FOR STARTUP, SH UTDOWNS, & MALFUNCTIONS

This section includes a descripti on of Boral Augusta Plant 5 standa rd 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 dire ctly to the atmosphere; and

o A situation that causes the reagent in jection 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 pr otect both the integrity of the control system and reduce the emissions to the atmosphere. Boral be lieves 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. Ve nting at too low a temperature could cause moisture to enter the system and cause th e lime to solidify. Venting at too high a temperature could damage the bags which woul d lead to visible and gaseous emissions. [It should be noted that Boral uses bags appr opriate 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 clea r 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 woul d 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 star t-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 operati on (when the temperature of the flue gas is in the right temperature range).

The standard start-up procedure for the kiln a nd 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 pr ocedure on the next page is based on a “cold

kiln/cold control” start.

 Hot kiln, cold control. The procedure on the next pa ge was followed, except that the exhaust air was immediately “up to te mperature.” (Initial System Start)

 Hot kiln, hot control. This would be a re-start afte r 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 proce dure would still run th rough the system checks, but most steps would be shortened since both the baghouse an d 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 procedur es for the kiln and lime injec tion 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 284 o 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 proc essing brick and start the pusher process. 6. Check DIFF operation and insure that all controls are prope rly operating. STARTUP - NORMALBORAL 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 prope rly 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 natu ral gas supply or electrical power, no new product is placed into or comes out of the kiln.

2. No new product is processed in th e kiln until a proper operational temperature is reached for pushing new product into the kiln. The minimum temperature required for th e 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 mate rial in the process. The fresh lime meter

can now be set to the normal flowrate set ting (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 th e kiln need to be stopped, the following general principles impact the procedures

 Unless a safety issue or control device integr ity issue occurs, the ki ln will continue to vent through the control device until the exha ust reaches the low temperature set point (284 o F).

 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 rout ine maintenance, the time will be documented as being part of the time allowed under the Rou tine 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 - NORMALBORAL 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 o F)

2. When kiln exha ust 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 th e kiln is stopped at the same time that the burners are stopped.

2. The kiln will continue to vent through th e 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 dama ge 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 prim ary 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 exhaus t 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 w ill operate in bypass until the situation is

controlled. SHUTDOWN

- EMERGENCYBORAL 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-August a Plant 5 has a responsibi lity to assure worker safety and to comply with all NFPA safety requir ements. 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 ba ghouse 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 in side the main plant facility to ensure that prompt attention can be given. There are a number of malfunctions that can trigger a fa ult within the system and trigger an alarm. Depending on the nature of the malfunction, the baghouse may or may not go to bypass immediately. Mo st of the faults begin as wa rnings of a minor malfunction that if not given attention w ill lead to a bypass of the syst em 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. T oo high or too low temperature to the baghouse will also lead to a bypass if they are not corr ected. The graphic displa y 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 pe rsonnel safety or equipment integrity in danger. A critical alar m will immediately cause the system to go into bypass and shutdown. This alarm is only triggere d when either personnel are in danger or the integrity of the system could be compromise d. Protecting the integrity of the system will ensure a more rapid return to normal operation of th e 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 duri ng 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- OVERVIEWBORAL 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 malf unctions 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-Augus ta 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 oper ating under normal conditions. As long as all reagent injection baghouse parameters are within normal operatin g ranges, the reagen t injection baghouse will continue to be operated during any malfunction of the kiln.

c. Boral-Augusta will either minimize the leng th of the control device downtime and bypass, or both, to the extent pr acticable 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 occurr ing, 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 even t 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 speci fics 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 malfun ction 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 assigne d are presented below. Boral Bricks has generated standard procedures that will be follow ed 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 sc rew 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 hi gh Audible alarm – Warning alarm at

16 mbar. Critical alarm at 20 mbar 17 Pressure drop across baghouse too lo w 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 bag house Critical alarm if >500 o F 20 Low temperature in baghouse Critical alarm if < 284 o F 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 c ontrol device. However with improper balance of air flows, there could be an improper

exhaust of kiln combustion z one 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 superv isor 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 DI FF to go to bypass to prevent damage. (Inlet temperature exceedances are addressed la ter in Kiln Malfunction 2 and DIFF Malfunction 20&21).

2. For the exhaust sent to the control device, vi sible emissions can be created by an out of balance malfunction. Prompt steps will be ta ken to correct the im proper balance. The continued operation of the control device will minimize all pollutant emissions.

3. If there is visible back-dra fting 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 emissi ons 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 1BORAL 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 reas ons 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 obser vation (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 de vice, Boral Bricks will work to get the kiln back to normal operating conditions as soon as feasib ly possible. The lim e injection baghouse system will be diverted from bypass back to the control device as soon as the problem is

corrected. KILN

MALFUNCTION 2BORAL 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 obser vation (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 se nsor 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, maintena nce 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, th e 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 s oon as received in the lime storage silo.

Steps Taken to Minimize Emissions:

1. If there are only alarm, light, or sensor pr oblems, these will be corrected to properly monitor the system. If the sy stem 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 emissi ons at or above the levels indicated in th e 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 1BORAL 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 obser vation (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 se nsor 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 te mporary bridging of th e material will be eliminated. If the problem occurs with freque ncy, additional devices will be installed to eliminate the problem. These new devices wo uld most likely have to be ordered and installed. More frequent at tention to this potential pr oblem 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 cont inuous as possible in the interim.

5. If there is insufficient lime in the silo, the pl ant 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 s oon as received in the lime storage silo.

Steps Taken to Minimize Emissions:

1. If there are only alarm, light, or sensor pr oblems, these will be corrected to properly monitor the system. If the sy stem 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 emissi ons at or above the levels indicated in th e 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 potentia l problem by observation would be required during this time and a schedule would be assign ed to the proper personnel to insure that

lime flow was as continuous as possible in the interim.

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

malfunction time. DIFF2

MALFUNCTION 2BORAL 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 obser vation (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 syst em will be analyzed and corrected to ensure proper electronic feedback to the computer system.

4. If the feed mechanism is not operating, the pl ant manager will be co ntacted immediately.

5. Key Boral Bricks personnel will id entify the cause of the problem.

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

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

to visit the site and ma ke 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 pr oblems, these will be corrected to properly monitor the system. If the sy stem 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 emissi ons at or above the levels indicated in th e 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 opera ble, 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 recy cled 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 woul d likely be to attempt to feed the lime at approximately twice the normal rate for a peri od of time that would equal to the time the unit operated without th e fresh lime addition. DIFF2

MALFUNCTION 3BORAL 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 obser vation (or alerted by an indicator light or alarm) and responds immediately.

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

3. If there is a sensor failure, the sensor syst em 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 id entify the cause of the problem.

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

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

to visit the site and ma ke 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 pr oblems, these will be corrected to properly monitor the system. If the sy stem 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 emissi ons at or above the levels indicated in th e 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. Du ring this time the control device will operate 100% on recycled lime. When the repair is co mpleted, 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 4BORAL 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 ex it 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 obser vation (or alerted by an indicator light or alarm) and responds immediately.

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

3. If there is a sensor failure, the sensor syst em 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 id entify the cause of the problem.

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

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

to visit the site and ma ke 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 probl ems, 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 f eed 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 pe rformance 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 dosi ng 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 recy cled 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 woul d likely be to attempt to feed the lime at approximately twice the normal rate for a peri od of time that would equal to the time the unit operated without th e fresh lime addition. DIFF2

MALFUNCTION 5BORAL 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 obser vation (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 syst em 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 wi ll be contacted immediately.

5. Key Boral Bricks personnel will id entify the cause of the problem.

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

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

to visit the site and ma ke 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 pr oblems, these will be corrected to properly monitor the system. If the sy stem 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 emissi ons at or above the levels indicated in th e 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 out side of the hoppe r, the unit can continue to operate using the existing filter ca ke 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, th e kiln will be operated as smoothly as possible to minimize emissions during the malfunction. DIFF2

MALFUNCTION 6BORAL 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 obser vation (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 syst em will be analyzed and corrected to ensure proper electronic feedback to the computer system.

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

5. Key Boral Bricks personnel will id entify the cause of the problem.

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

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

to visit the site and ma ke adequate repairs.

8. Used lime will be recycled th rough 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 pr oblems, these will be corrected to properly monitor the system. If the sy stem 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 emissi ons at or above the levels indicated in th e 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 r ecirculating screw is not operabl e, 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 fo r some portion of the repair procedure.

3. During any bypass or control device shutdown, th e kiln will be operated as smoothly as possible to minimize emissions during the malfunction. DIFF2

MALFUNCTION 7BORAL 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 obser vation (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 syst em 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 id entify the cause of the problem.

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

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

to visit the site and ma ke 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 malfunc tion 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 po ints. 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 th e baghouse until an undesirable pressure drop is achieved in th e baghouse. Even though the pressure drop might increase, the control efficiency s hould 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 baghous e outlet poppet valves open.

5. If an undesirable pressure drop is met or ex ceeded, 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 8BORAL 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 de vice 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 op timal 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; se al 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 obser vation (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 syst em 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 id entify the cause of the problem.

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

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

to visit the site and ma ke 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 malfunc tion 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 inj ection 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, th e kiln will be operated as smoothly as possible to minimize emissions during the malfunction. DIFF2

MALFUNCTION 9BORAL 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. com ponent 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 obser vation (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 component s associated with the lime injection baghouse system.

3. If there is a sensor failure, the sensor syst em will be analyzed and corrected to ensure proper electronic feedback to the computer system.

4. If there are mechanical and electrical compone nt failures, the plant manager will be contacted immediately.

5. Key Boral Bricks personnel will id entify the cause of the problem.

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

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

to visit the site and ma ke 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 malfunc tion as defined in §63.2 and there are no additional steps to minimize emissions.

2. If there is a failure of th e mechanical and electrical co mponents, Boral Bricks will attempt to fix the failure while continuing to operate the lime in jection baghouse system as long as all other operating parameters ar e 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 mechani cal and electrical component failure cannot be corrected while operating the lime in jection 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 operat ed as smoothly as possible to minimize emissions during the malfunction. DIFF2

MALFUNCTION 10BORAL 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 temperat ure 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 obser vation (or alerted by an indicator light or alarm) and responds immediately.

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

3. If there is a sensor failure, the sensor syst em 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 id entify the cause of the problem.

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

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

to visit the site and ma ke 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 malfunc tion as defined in §63.2 and there are no additional steps to minimize emissions.

2. If there is ductwork failure, Boral Bricks wi ll attempt to fix the failure while continuing to operate the lime injection baghouse system as long as all othe r operating parameters are within desirable operating ranges.

3. If the failure of the ductwo rk cannot be corrected whil e 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, th e kiln will be operated as smoothly as possible to minimize emissions during the malfunction. DIFF2

MALFUNCTION 11BORAL 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 obser vation (or alerted by an indicator light or alarm) and responds immediately.

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

3. If there is a sensor failure, the sensor syst em will be analyzed and corrected to ensure proper electronic feedback to the computer system.

4. If there is a damper component failure, th e plant manager will be contacted immediately.

5. Key Boral Bricks personnel will id entify the cause of the problem.

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

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

to visit the site and ma ke 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 malfunc tion 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 ope ration, the baghouse will be bypassed.

4. During any bypass or control device shutdown, th e kiln will be operated as smoothly as possible to minimize emissions during the malfunction. DIFF2

MALFUNCTION 12BORAL 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 covere d 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 obs ervation (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 syst em will be analyzed and corrected to ensure proper electronic feedback to the computer system.

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

5. Key Boral Bricks personnel will id entify the cause of the problem.

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

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

to visit the site and ma ke 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 th e 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 desi rable operating ranges.

2. If the electrical component failure cannot be corrected wh ile operating the lime injection baghouse system, the lime injection baghouse sy stem 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, th e 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 sens or or indicator malfunction that affect compliance status will be record ed under this Malfunction No. 14. DIFF2

MALFUNCTION 13BORAL 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: Disc harge 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 obser vation (or alerted by an indicator light or alarm) and responds immediately.

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

3. If there is a sensor failure, the sensor syst em 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 re pair 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 malfunc tion as defined in §63.2 and there are no additional steps to minimize emissions.

2. If the discharge valve is not operable, re agent 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 valv e 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, th e kiln will be operated as smoothly as possible to minimize emissions during the malfunction. DIFF2

MALFUNCTION 14BORAL 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 reagen t 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 obs ervation (or alerted by a change in operating parameters) and responds immediately.

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

3. If there is a sensor failure, the sensor syst em will be analyzed and corrected to ensure proper electronic feedback to the computer system.

4. If there is a bag failure, the plant mana ger will be c ontacted 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 malfunc tion 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 repla cement, 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, th e kiln will be operated as smoothly as possible to minimize emissions during the malfunction. DIFF2

MALFUNCTION 15BORAL 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 orinsufficient 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 baghous e. 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 properl y Increase cleaning frequency Increase compressed air pressure

Insufficient compressed air pr essure 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 16BORAL 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 indicate s excessive reagent on the bags, exhaust will continue to flow through the system unle ss it will cause a danger to personnel or the equipment. This will ensure that the maximum possible emissi on 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, th e 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 baghous e. 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 st art-up procedures, if the system was shut

down.

Steps Taken to Minimize Emissions:

1. Increasing the reagent feed helps build the reag ent cake up on the bags faster. The increase builds it up as soon as possible without causing ot her 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 17BORAL 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: Visi ble Emissions from Stack

Possible Causes: Bag breakage; improper duct ba lancing; improper seal at tube sheet; insufficient filter cake Type of Alarm: Visual observation. No al arm 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 clos e off one module at a time until location of

leak can be determined.

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

4. If the issue is other than bag breakage, determ ine 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 thr ough 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 repa ired, follow start-up procedures.

Steps Taken to Minimize Emissions:

1. Boral - Augusta will seek to identify whet her 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 th rough the remaining modules.

2. If the malfunction can only be fixed by s hutting the baghouse down, Boral - Augusta will bypass the baghouse and will correct the problem

3. During any bypass or control device shutdown, th e kiln will be operated as smoothly as possible to minimize emissions during the malfunction. DIFF2

MALFUNCTION 18BORAL 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 o F (“High-high temperature”)

Steps Taken to Correct Problem:

1. If critical alarm, DIFF will automatically sw itch 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 contro l device integrity issue.

3. Depending on root cause, follow remedy step s 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 repa ired, follow start-up procedures.

Steps Taken to Minimize Emissions:

1. Boral - Augusta will respond to the indicator al arm as soon as practicab le to help ensure

that the Critical Al arm 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, th e kiln will be operated as smoothly as possible to minimize emissions during malfunction. DIFF2

MALFUNCTION 19BORAL 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 fl owing to control device

3. Determine if exhaust can still safely vent through one or more baghouse modules. If so, continue to vent through baghous e. If not, switch to bypass mode.

4. Depending on root cause, follow remedy step s 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 repa ired, follow start-up procedures.

Steps Taken to Minimize Emissions:

1. If the temperature is sufficient in any modul e, 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, th e kiln will be operated as smoothly as possible to minimize emissions during malfunction. DIFF2

MALFUNCTION 20BORAL 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 Automa tic 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 wi ll 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 confir m that all default settings have been reset to the correct opera ting 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 21BORAL 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 e quipment 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 a ttempt to reinstall/restart; and

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

 Suspend operations as soon as practicable un til compliance can be assured if failure cannot be repaired in a timely manner. ACTS OF GODBORAL 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 e quipment 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 s ource 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 th e power loss is only at the baghouse unit,

there will be no exhaust from the kiln and th e kiln will automatically stop and will not operate until the situation is corrected. LOSS OF POWER/GASBORAL BRICKS Augusta Plant 5

Page 44 of 47 BORA-3_Augusta 5 SSMP.doc Revision 2- July 2, 2007 

### SECTION 6.0- RESPONSIBILITI ES 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 responsibili ties, 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 VERSIO N CONTROL PROCEDURES

Protocol for identifying when to update the pla n, managing previous vers ions 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 s hutdowns of the machines

 Record of each malfunction, and whether the ac tions 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 malf unction, 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 th e owner/operator or other responsible official;

o Statement that the actions taken during th e malfunction were consistent with the Malfunction Plan;

o The number, duration, and a brief descripti on of malfunction that occurred during the reporting period (§63.10(d)(5)(i)) or a c opy 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 para meter monitoring exceedances are believed to have occurred during the ma lfunction (§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 th is SSMP, because the plan did not address the type of malfunction th at occurred and/or the actions taken were not included in the current SSMP, and excess emissions occurred, the Environmental Supervisor should report the actions take n 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 incl ude the following information (§63.10(d)(5)(ii)):

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

o Explanation of the circumst ances 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 o ccurred, and the Boral-Augusta Plant 5’s SSMPBoral 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 fu ture events. Then General Provisions also require ((§63.6( e)(3)(viii)):

o Revise the SSMP within 45 days after th e 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 o ccurs - 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/wri tten notification required within 2 days of malfunction not included in SSMP; written notific ation 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

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### SSM E VENTSBoral 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 answ ers 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 comp lete 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 inco rporate this malfunction (see Section 7.1)Boral Bricks, Inc.Augusta Plant 5 PlantIncident/Malfunction Tracking LogDateTrackingNumberWas theIncident aMalfunction?If YES, wasthe SMMPfollowed?If SSMP not followed....Who completedthis log?SeeNote1Was 2nddayreport calledin or faxed?Was 7thdayreport mailedWas SSMPmodified?1Add a reference letter to this column, ifyou 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” NotesBoral Bricks, Inc. Augusta Plant 5 Plant

NOTIFICATION REPORT FOR MALFUNCTIONS NOT COVERED BY SSMP

Type of Malfunction:

Date of Malfunction:

Explanation of the circumst ances 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 se ven (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

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### R EPORTS

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### SSM P LAN