Startup, Shutdown and Malfunction Plan In Accordance with Brick and Structural Clay

National Emission Standard for Hazardous Air Pollutants

For

BORAL BRICK

SMYRNA FACILITY SMYRNA, GEORGIA

LAST REVISED July 2007

Responsible Official Signature

________________________________________________________________________ Corben Pate Plant Manager DateTABLE OF CONTENTS

SECTION 1.0- INTRODUCTION ................................................................................................. 1

SECTION 2.0- PURPOSE .......................................................................................................... .... 2

SECTION 3.0 - REGULATORY ANALYSIS .............................................................................. 3

SECTION 3.1 DEFINITION OF “MALFUNCTION” ......................................................... 3

SECTION 4.0- AFFECTED SOUR CES AND CONTROL DEVICES ......................................... 5

SECTION 5.0- PROCEDURES FOR STARTUP, SHUTDOWNS, & .......................................... 6

MALFUNCTIONS .................................................................................................................. ....... 6

SECTION 5.1- STARTUP PROCEDURES............................................................................... 7

SECTION 5.2- SHUTDOWN PROCEDURES ....................................................................... 11

5.2.1 Normal Shutdown Procedures ............................................................ 11

5.2.2 Emergency Shutdown Procedures ...................................................... 14

SECTION 5.3- MALFUNCTION PROCEDURES ................................................................. 15

SECTION 6.0- RESPONSIBILITIES AND POINTS OF CONTACT........................................ 47

SECTION 6.1- ORGANIZATIONAL CHART ....................................................................... 47

SECTION 6.2- RECORDKEEPING PLAN ............................................................................. 47

SECTION 6.3- TRAINING REQUIREMENTS ...................................................................... 47

SECTION 6.4- SSMP VERSION CONTROL PROCEDURES .............................................. 47

SECTION 7.0- RECORDKEEPING AND REPORTING REQUIREMENTS ........................... 48 SECTION 7.1- OVERVIEW OF REQUIREMENTS .............................................................. 48

SECTION 7.2- EXAMPLE REPORT FORMS........................................................................ 50

7.2.1 Malfunction reports (internal) ............................................................. 50

7.2.2 Malfunction Log ................................................................................. 50

7.2.3 Example Notifications ........................................................................ 50

7.2.4 Addresses ............................................................................................ 50

Appendix A – SSMP Reports Incident Report Form Incident/Malfunction Tracking Log Startup Shutdown Log Notification Report for Malfunctions not Covered by SSMP Appendix B – Trouble Shooting Procedures Appendix C - Semi Annual Reports Appendix D – Previous Versions of SSMPRevision to SSMP:

Date of Revision Reason for Revision July 5, 2006 Original SMMP April 20, 2007 Revised Lime fl ow too low and/or stopped

incident to include all incidents where lime flow is slowed or stopped; included reference to Bundy manual for procedures for shutting

down lime feed May 1, 2007 Corrected typos, cl arified language (no major changes) June 19, 2007 Addition of start up procedures for bringing one kiln back to operational while the other

kiln and the control are already operating July 2, 2007 Plan revised/ updated based on NOV from GA DEP (March 2007)Startup, Shutdown and Malfunction Plan Boral Bricks, Inc. Smyrna Plant

Page 1 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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 Smyrna facility tunnel kilns (Kiln 1 a nd Kiln 2) and the reagen t injection fabric filter (DIFF) system, which are the aff ected sources in the Subpart JJJJJ.

At all times, including periods of startup, shutdown, and malfuncti on, Boral Bricks, Inc. (BoralSmyrna) will operate and maintain any air pollution control equipment and monitoring equipment that are used to comply with the standa rd in a manner consiste nt with safety and good air pollution control practices fo r minimizing emissions to the le vels required by the relevant standards (i.e., meet the emission standard or co mply with the SSMP). Determination of whether such operation and maintenance procedures are bei ng used will be based on information that may include, but is not limited t o, monitoring 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-Smyrna 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 Kiln 1, Kiln 2 and the control device are being started, shutdown, and during malfunctions. Boral-Smyrna 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, Inc. Smyrna Plant

Page 2 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 

### SECTION 2.0- PURPOSE

Under 40 CFR 63.6(e), Boral-Smyrna is required to develop and implement for Kiln 1 and Kiln 2, and control device a written SSMP that describe s, in detail: (1) pro cedures for operating and maintaining the source during periods of startu p, shutdown, and malfunction; (2) a program of

corrective action for a malfuncti oning process; and (3) the air pollution control and monitoring equipment used to comply with the relevant standard. The purpose of the SSMP is to:

(A) Ensure that, at all times, Boral-Smyrna operates and maintains air pollution control and monitoring equipment in a manner consistent with safety and good air pollution control practices for minimizing emissions to the levels required by the relevant standards;

(B) Ensure that Boral-Smyrna is prepared to co rrect malfunctions as soon as practicable after

their occurrence in order to minimize excess em issions 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, Inc. Smyrna Plant

Page 3 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 

### SECTION 3.0 - REGU LATORY 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-Smyrna develop and implement a SSMP for operations used to comply with the Brick and Structural Clay NESHAP. This SSMP is intended to meet the requirements for Boral-Smyrna kiln operations.

 §63.6(e)(3) of Subpart A, General Provisions, requires Boral-Smyrna 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-Smyrna is also required under §63.6(e )(3)(vii) to perform the followi ng activities or functions:

o Keep records of any malfunction event that occurs and keep records of the actions taken to minimize emissions during the event.

o Submit reports if procedures taken during the event are not consistent with the procedures that are included in the SSMP and excess emissions occurred.

o Revised 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.

o Update the plan if requested by EPA or the appropriate State or Local Air Pollution Control Authority.

SECTION 3.1 DEFINITION OF “MALFUNCTION”

During the course of normal operations, Boral- Smyrna 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 re asonably preventable failure of air pollution control and mon itoring equipment, process equipment, or a process to opera te in a normal or usual manner which causes, or has the potential to cause, the emission limitations in an applicable standard to be exceeded. (§63.2).

As stated above, a malfunction, as defined under 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, Inc. Smyrna Plant

Page 4 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Boral-Smyrna also has a separate plan for routine maintenance of Kiln 1, Kiln 2 and control

device covered under the Brick and Structural Clay NESHAP that is called our Operating, Monitoring, and Maintenance Plan (OMMP). According to our OMMP, routine maintenance operations must be performed in accordance w ith the equipment manufact urer’s specifications and recommendations, as well as the procedures speci fic to Boral-Smyrna that are detailed in our

OMMP.Startup, Shutdown and Malfunction Plan Boral Bricks, Inc. Smyrna Plant

Page 5 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 

### SECTION 4.0- AFFECTED SO URCES AND CONTROL DEVICES

This plan covers the following devices:

General Description: Kilns 1 and 2 controlled by a single Reagent Injection Fabric Filter Systems (DIFF)

Affected Source: Tunnel Kilns -K iln 1 (EU01), Kiln 2 (EU02)

Capture/Control/Monitoring Device ID: Reagen t Injection Fabric Filter System (DIFF-01) (also referred to as Reagent Injection Baghouse System) Brief Description of System:

Due to the site-wide potential emissions of HF, HCL and total HAP, the Boral-Smyrna facility is a major source of HAP.

The tunnel kilns were operating prior to the pr omulgation date of July 22, 2002, and thus the kilns 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 kilns 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-Smyrna elected to add a reagent injectio n baghouse system in order to comply with the

above limits.Startup, Shutdown and Malfunction Plan Boral Bricks, Inc. Smyrna Plant

Page 6 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 

### SECTION 5.0- PROCEDURES FO R STARTUP, SHUTDOWNS, &

MALFUNCTIONS

This section includes a description of Boral-Sm yrna standard procedures for starting Kiln 1 (EU01), Kiln 2 (EU02), and reagent injecti on baghouse system, shutting down the kilns and reagent injection ba ghouse system, and for dealing with malfunctions that occur. For the purposes of this plan, the malfunctions include onl y those incidents that have the potential to cause an exceedance of the emission or operati ng limits. These situations would include:

o A situation that causes the emissions fr om Kiln 1 and Kiln 2 tunnel kilns to bypass the control device (DIFF-01) and be vented directly 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 one procedure for start-up, a regular shutdown pro cedure, an emergency shutdown procedure (i.e., “hard shutdown”) and numerous malfunction scenarios.Boral Bricks, Inc. Smyrna Plant

Page 7 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 SECTION 5.1- STARTUP PROCEDURES

The startup procedures for the kiln s and reagent injection fabric fi lter system are outlined below. Boral-Smyrna will document each time the systems undergoes startup.

Steps for Startup for Both Kilns Notes Prior to starting the baghouse system, the kiln should be brought up to temperature through the bypass to avoid damage to the bags. Bypass DIFF until the kiln exhaust temperature exceeds 350 o F.

1. Prior to starting the system, the baghouse hopper

heaters should be enabled. This will assist in pre-heating the baghouse. Each module’s hopper heater is enabled individually from the touch

screen. The heaters will then turn on and off automatically in response to a signal from the

local thermostat. The system start-up is semi-automatic from the main touch screen. However, the operator has the ability to control each piece of equipment manually as well.

2. Reset the main gas valve and restart air compressor if necessary.

3. At the initiation of th e start-up process, the following conditions should exist: (1) Compressed air available and turned on (2) Hopper heaters enabled (3) Bypass is “OPEN” (4) Four baghouse modules “INACTIVE” (5) Reagent blower in “HAND/STOPPED” (6) Reagent Feeder in “HAND/STOPPED” (7) All hopper rotary ai rlock local switches in “MANUAL”. The rotary airlocks will run continuously whenever the following conditions are met: (a) Local switch in “AUTO” (b) Module is “ACTIVE” (8) All hopper vibrator local switches in “AUTO”. The vibrators will cycle on and off whenever their respective airlock is operating (9) Baghouse cleaning in “OFF”.

4. The kiln exhaust fans and the I.D fan at the baghouse start with the baghouse in bypass mode and the kiln go through a purge cycle for safety. 5. The burners are ignited and the kiln heat up with the baghouse in bypass. Bypass DIFF until the kiln exhaust temperature exceeds 350 o F. In the event that the minimum temperature is not reached, the kiln will normally not be hot enough for the normal resumption of STARTUP - NORMALBoral Bricks, Inc. Smyrna Plant

Page 8 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Steps for Startup for Both Kilns Notes processing of brick. No new product will

be introduced to the kiln and thus emissions will be minimized during this time. When the proper temperature is reached, the baghouse will be placed back into automatic operation and production

will resume. 6. Once kiln operation is stable the baghouse

modules can be made ACTIVE. Each module is activated individually. When the inlet valve and outlet poppet OPEN limit switches are both made,

the module ACTIVE indication will be illuminated

on the touch screen. 7. After all baghouse modules are active, switch the bypass in AUTO. It will automatically close as long as the following conditions are met: (1) I.D. fan is running (2) At least one baghouse module is proven ACTIVE (3) Compressed air pressure above the LOW-LOW set point (4) Baghouse inlet temperature above the LOW-LOW set point (5) Baghouse inlet temperature below the HIGH-HIGH set point. This automatic process ensures that the exhaust is vented as soon as practicable.

8. Once the bypass is closed, the module will be allowed to operate for a minimum of one hour

with no lime feed to allow moisture to be

removed. 9. Set lime feed rate at the computer module, place

lime feed and lime blower in “AUTO”. After the reagent blower has been operating for at least 15 minutes the reagent feeder will start. This ensures that there is no blockage in

the line and that all the moisture has been purged

10. Heat kiln up until the temperature is sufficient to begin processing brick and start the pusher

process. 11. Check reagent injection fabric filter operation and insure that all controls are properly operating.Boral Bricks, Inc. Smyrna Plant

Page 9 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Steps for Startup for One Kiln Notes

1) Complete startup of kiln 1 as far as possible without starting kiln 1 exhaust

fan. 2) Halt lime feed to DIFF. [This is to prevent lime feeding into unheated modules, which could cause control to malfunction] 3) Place out of service modules in service. Allow 1 hour of operation to heat module internals. [This prevents condensation damage from occurring within the module.] 4) Start kiln 1 exhaust fan at low rpm and

remove dilution fan from service. 5) While kiln 1 startup in progress monitor DIFF inlet temperature. If inlet temperature cannot be stabilized at or

above 275 o F bypass DIFF to avoid

malfunction. 6) If inlet temperature stabilized above 275

o F, restart lime feed at 40 on VFD. 7) If DIFF bypassed, monitor kiln 1 exhaust temperature. Attempt restart of DIFF when

kiln 1 exhaust achieves 150 o F. 8) If inlet temperature does not stabilize

above 275 o F, bypass DIFF and attempt restarts every 50 o F rise in kiln 1 exhaust. 9) Once DIFF returned to service allow 1

hour to reheat module internals and start

lime feed at VFD = 40. 10) Monitor DIFF inlet temperature during kiln 1 startup. Return dilution fan to service when inlet temperature exceeds

390 o F. 11) Record action in Start-Up Log.Boral Bricks, Inc. Smyrna Plant

Page 10 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Steps for Startup after Short Stoppage – Power Outage Notes

1. Restart air compressor

2. Restart the kilns exhaust fan 3. Check for air leaks by performing walk through 4. Assuming the exhaust temp is greater than 350 F then take the bypass switch to AUTO. 5. When the bypass valve is closed turn the ID Fan

and Dilution Fan from HAN to AUTO.

6. Check that lime feeder rate and lime blower are

in auto 7.Proceed with kiln re-lightof burners and re-start push

Steps Taken to Minimize Emissions:

1. When there is any type of malfunction of the k iln that results in the kiln stoppage such as interruption of natural gas s upply or electrical power, no new product is placed into or

comes out of the kiln.

2. No new product is processed in the kiln unt il a proper operational temperature is reached for pushing new product into the kiln. The mi nimum temperature requi red for the fabric filter operation will be re ached before the kiln is at a pr oper temperature for introduction of new product. With no new product being introduced to the kiln, the leve l of emissions will be continually decreasing until the pushing of new production resumes.Boral Bricks, Inc. Smyrna Plant

Page 11 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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 (275 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 # 3505.

5.2.1 Normal Shutdown Procedures for Two Kilns

The normal shutdown procedures for the kiln an d reagent injection baghouse system are listed below. Boral-Smyrna will document each time the system is shutdown.

Steps for Kiln Shutdown of Both Kilns 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 The system shut down will be manual from the main control panel. The operators will stop or disable each piece of equipment individually. Steps for Long Term DIFF Shut Down Notes Following is the procedure for shutting the system down for a short period of time (typically less than 8 hours) 1. Turn off the reagent feeder 2. Turn off the reagent blower. Allow the blower

to run for at least 5 minu tes after the feeder has been shut off to purge the conveying line. 3. Allow module to operate until the low temperature is hit. SHUTDOWN

- NORMALBoral Bricks, Inc. Smyrna Plant

Page 12 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 4. Open the bypass valve. 5. Once the bypass valve is fully open, turn each of the baghouse modules to INACTIVE. Verify that the baghouse module inlet and outlet valves close. 6. Leave the hopper heat operating. 7. Put in manual clean mode Caution: waste lime bags will fill very rapidly. 8. Turn the rotary airlock local switches to HAND. This will allow the airlocks to continue to operate even though the ba ghouse is inactive.

9. If maintenance on a m odule is required, disable the hopper heat and rotary airlock for that module.

5.2.2 Normal Shutdown Procedures for One Kiln

This is also the emergency shutdown on one kiln

Steps for Kiln Shutdown of 1 Kiln Notes

1. Initiate shutdown of single 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 The system shut down will be manual from the main control panel. The operators will stop or disable each piece of equipment individually. Steps for Long DIFF Shut Down Notes Following is the procedure for shutting down two modules of the system for a short period of time (typically less than 8 hours)

1. Reset the lime feed for one kiln ope ration. Out of serv ice kiln is not pushing product, i.e., no

exhaust.

2. Put exhaust fan for the out of service kiln to

“OFF”

3. Remove the modules 410 and 430 for services and change to INACTIVE. Preferred modules to operate in 1 kiln mode

420 and 440

4. Monitor the out of service kiln exhaust

temperatureBoral Bricks, Inc. Smyrna Plant

Page 13 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 5. Place in Manual Feed 6. Turn the rotary airlock local switches to HAND. This will allow the airlocks to continue to operate even though the ba ghouse is inactive.

7. If maintenance on a m odule is required, disable the hopper heat and rotary airlock for that module.

Steps Taken to Minimize Emissions:

1. The introduction of new product into the ki ln is stopped at the same time that the burners are stopped. This results in a continual decrease of emissions until the exhaust fan is stopped.Boral Bricks, Inc. Smyrna Plant

Page 14 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 5.2.3 Emergency Shutdown Procedures

The emergency shutdown procedures for the kiln and reagent injection baghouse system are listed below. Boral-Smyrna will document each time there is an emergency shutdown. Emergency shutdown is triggered automatically by the system when it senses conditions that can lead to imminent danger or damage to equipment. This type of shutdown is exactly the same as is listed previously in section 5.2.1 & 5.2.2.

Steps Taken to Minimize Emissions:

 In an emergency shutdown, safety is the pr imary issue. Boral-Smyrna 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, Inc. Smyrna Plant

Page 15 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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-Smyrna has a responsibility to assure worker safety and to comply with all NFPA safety requirements. This will often affect the approach that must be taken to rectify a malfunction situation. Boral- Smyrna will work to minimize emissions at all times, while ensuring all other health a nd safety requirements are also met.

Any malfunction of the ba ghouse initiates an alarm:

1. WARNING ALARM: This is an audible alarm and a light will fl ash. 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 corre cted. These conditions both have an alarm set point to give a warning before reaching the critical bypass set point. The graphic display will

show the nature of the malfunction and indicate the part of the device th at needs attention.

Boral-Smyrna’s approach for minimizing emissi ons during any malfunctions are based on the following concepts:

1. Minimize the amount of time the system is shut down . To minimize the amount of time the kilns and the DIFF systems are shutdown, Boral-Smyrna 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.

c. Boral-Smyrna 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-Smyrna will: MALFUNCTIONS- OVERVIEWBoral Bricks, Inc. Smyrna Plant

Page 16 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 a. In any instance where the kiln is operating under normal conditions but the reagent injection system is malfunctioning, Boral-Smyrna 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-Smyrna 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-Smyrna will either minimize the length of the control devi ce downtime and bypass, or both, to the extent practi cable 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-Smyrna 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 Bricks, Inc. Smyrna Plant

Page 17 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 For purposes of this plan, a list of the types of potential malfunctions that can occur, the primary alarm type, and the Malfunction Number assigned are presented below. Boral-Smyrna 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.

KILN 1 and 2 MALFUNCTIONS

MALFUNCTION

NUMBER MALFUNCTION NAME Type of Alarm

1 Flashing System (including solenoid valves, timers, pressure regulators) None – visual observationPossible temperature alarm 2 Kiln out of Balance (improper balance of air flow ) (out of dryer stack) None – Visual observation

3 Kiln Malfunction that causes a bypass of Reagent Injection Fabric Filter System Visible and audible alarm if burners are out or high temperature alarm condition.

REAGENT 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) Audible and visible alarm.

2 No Reagent Feed – Bridging of reagent

within the silo. None – Visual observation

3 Failure of fresh reagent silo feed mechanism that feeds dosing screw Audible and visible alarm.

4 Failure of reagent dosing screw metering and feed system Audible and visible alarm.

5 Failure of the reagent fill pipe feed

system. None –Visual observation

6 Failure of compressed air syst em Audible and visible alarm. 7 Bag cleaning system failure Audible and visible alarm. 8 Mechanical and Electrical Components – Failure of Motors, Fans, Valves, Bearings, Belts, etc. Audible and visible alarm. (Depending on extent of failure.)

9 Ductwork Failure Vsible alarm. 10 Damper/ damper Drives failure Audible and visible alarm.Boral Bricks, Inc. Smyrna Plant

Page 18 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 MALFUNCTION

NUMBER MALFUNCTION NAME Type of Alarm

11 Electrical Controls Failure (thermocouple, pressure transmitter in duct) Audible and visible alarm. (Depends on component failing.)

12 Failure of the discharge rotary valve to the big bag or other collection device. Audible and visible alarm.

13 Bag Failure- Manufacturers Defect, High Pressure Drop, Temperature, hole Visual observation or alarm

14 Pressure drop across baghouse too high Indicator – 6”wc 15 Pressure drop across baghouse too low Visual Observation

16 Visible emissions from stack None – visible inspection 17 High temperature in baghouse System alarm at 400 o F

Critical alarm if >425 o F 18 Low temperature in baghouse System alarm at 300 o F

Critical alarm if < 275 o F

19 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, Inc. Smyrna Plant

Page 19 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Description of Equipment: The flashing system, a key component of the kiln, uses natural gas in excess of normal usage, to “flash” the brick in a zone of the kiln. This flashing provides a coloring

finish and/or texture finish. A malfunction of this system can provide an excessive amount of smoke from either the kiln exhaust stack, the dryer exhaust stack, or the holding

room exhaust stack. Type of Malfunction: Flashing System

Possible Causes: Part failure such as timers, pressure regulators and solenoid valves, PLC components, wiri ng, or networking problems. 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 (or aler ted by an indicator light or alarm) and responds immediately. This could be observed as smoke out of one of the exhaust stacks or smoke within the plant. The malfunction could be a failure of the flashing to activate and would not cause visible emissions, but could cause the kiln car pusher to be stopped until proper repair is made.

2. Staff will identify the source of the smoke and take immediate action to stop the operation of the device ca using this condition.

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

electronic feedback to the computer system.

4. If possible, the flashing system will be corrected while operating the kiln.

5. If the excessive smoke problem cannot be corrected while operating the kiln, BoralSmyrna will follow one of the shutdown procedures identified in this SSMP.

6. If the flashing system is working properl y, any systems stopped for repair will be

restarted.

Steps Taken to Minimize Emissions:

1. Boral-Smyrna will continue to operate the control device as long as there is no inlet temperature variance that requires the ba ghouse to go to bypass to prevent damage. (Inlet temperature exceedances are addr essed later in Kiln Malfunction 3, DIFF Malfunction 17, and DIFF Malfunction 18).

2. The continued operation of the control device will minimize all pollutant emissions. Only visible emissions should be aff ected by a flashing system malfunction.

3. Boral-Smyrna will consider the flashing system to be a malfunction if there are visible emissions as identified by Method 22 during such episode. As long as all control device operating parameters are within desira ble ranges, the control device will be operated to minimize emissions. KILN

MALFUNCTION 1Boral Bricks, Inc. Smyrna Plant

Page 20 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 4. If there are no visible emissions in accord ance with Method 22, the above occurrence will be documented, but will not be consider ed a malfunction as identified in §63.2 and will not be reported as such.Boral Bricks, Inc. Smyrna Plant

Page 21 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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 the kiln is out of balance, the kiln fire man will check exhaust fan speed and correct if

necessary. 3. Key Boral-Smyrna staff will identify the cause of the out of balance problem.

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

5. If the balance problem cannot be corrected while operating the kiln. Call supervisor (NOTE: If the kiln fan is off the kiln will automatically shutdown).

6. Boral-Smyrna will follow one of the shutdown procedures identified in this SSMP.

Steps Taken to Minimize Emissions:

1. Boral-Smyrna will continue to operate the co ntrol device as long as there is no inlet temperature variance that requires the baghous e to go to bypass to prevent damage. (Inlet temperature exceedances are addressed late r in Kiln Malfunctio n 3, DIFF Malfunction 17, and DIFF Malfunction 18).

2. For the exhaust sent to the cont rol device, only visible emissi ons should be affected by an out of balance malfunction. The continued ope ration of the control device will minimize all pollutant emissions.

3. If there is back-drafting through the dryer, Boral-Smyrna will consider such occurrence a malfunction as described herein. If operati ng parameters are acceptable, Boral-Smyrna will continue to operate the c ontrol device to minimize emissions from the kiln exhaust. (New plant only)

4. If there is no back-drafting through the drye r, Boral-Smyrna will consider the balance problem to be malfunction if there are vi sible emissions as identified by Method 22 during such episode. As long as all control device opera ting parameters are within desirable ranges, the control device will be operated to minimize emissions. (New plant only) KILNM ALFUNCTION 2Boral Bricks, Inc. Smyrna Plant

Page 22 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 5. If there is no back-drafting through the dr yer and if there are no visible emissions in accordance with Method 22, the above occurr ence will be documented, but will not be considered a malfunction as identified in §63. 2 and will not be repo rted as such. (New plant only)Boral Bricks, Inc. Smyrna Plant

Page 23 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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 the Reagent Injection Fabric Filter System Possible Causes (not complete): Excessive Inlet Temperature Type of Alarm: WARNING ALARM Visible and audible alarms at the baghouse 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 or assistant plant manager will be contacted immediately.

4. Key Boral-Smyrna 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-Smyrna will follow one of the shutdown proce dures identified in this SSMP.

Steps Taken to Minimize Emissions:

1. During a bypass of the control device, Boral-Smyrna will work to get the kiln back to normal operating conditions as soon as feasibly possible. The reagent injection baghouse system will be diverted from bypass back to the control device as soon as the problem is

corrected. KILN

MALFUNCTION 3Boral Bricks, Inc. Smyrna Plant

Page 24 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Description of Equipment: The reagent injection fabric filter system requires free flowing reagent. The system is equipped with a reagent silo to provide this reagent. There are sensors and level indicators within and below the silo to monitor free flowing

reagent. Type of Malfunction: No Reagent Feed Possible Causes (not complete): Failure of sensor monitoring free flowing reagent; Failure of Level Indicator; Reagent availability issue. Type of Alarm: WARNING ALARM Audible and visible alarm at both the baghouse 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 reagent, that the sensor has failed, or that there is no fresh reagent available.

3. If there is free flowing reagent, the reagent fl ow sensor system and level indicator sensors will be analyzed and corrected to ensure proper feed to the computer system.

4. If there is no free flowing reagent, 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 reagent in the silo, the plant manager will be contacted immediately.

6. Key Boral-Smyrna personnel will contact re agent suppliers and will have reagent expedited to the site.

7. Reagent will be fed into the system as soon as received in the reagent 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 w ith sufficient reagen t 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 reagent in the silo, Boral-Smyrna will stop bag cleaning to preserve the reagent in the filter cake on the bags. When new reagent is available the cleaning will remain off until the pressure drop is 2” of water column. DIFF

MALFUNCTION 1Boral Bricks, Inc. Smyrna Plant

Page 25 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Description of Equipment: The reagent injection fabric filter system requires free flowing reagent. The system is equipped with a reagent silo to provide this reagent. There are sensors and level indicators within and below the silo to monitor free flowing

reagent. Type of Malfunction: No Reagent Feed Possible Causes (not complete): Bridging of reagent within the hopper over the feed

mechanism. Type of Alarm: None – Visual observation only

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 reagent.

3. 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 reagent flow was as c ontinuous as possible in the interim.

4. If there is insufficient reagent in the silo, the plant manager will be contacted immediately.

5. Key Boral-Smyrna personnel will contact re agent suppliers and will have reagent expedited to the site.

6. Reagent will be fed into the system as soon as received in the reagent 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 w ith sufficient reagen t 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 reagent flow was as continuous as possible in the interim. DIFF

MALFUNCTION 2Boral Bricks, Inc. Smyrna Plant

Page 26 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Description of Equipment: On the bottom of the reagent storage silo, there is a feed mechanism (Bin vibrator), wh ich shakes lime down and discharges the reagent to the bottom of the silo into the dosing screw. Type of Malfunction: Failure of fresh reagent silo feed mechanism that feeds dosing screw Possible Causes (not complete): Feed mechanism 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 free flowing reagent.

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-Smyrna personnel will identify the cause of the problem.

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

7. If non-repairable by Boral-Smyrna staff, the vendor or its repr esentatives will be

contacted to visit the site and make adequate repairs.

8. Reagent 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 w ith sufficient reagen t 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 op erable, Boral-Smyrna will stop bag cleaning to preserve the reagent in the filter cake on the bags. When the repair is completed, the bags will be cleaned and the reagent feed will be increased until the normal operating pressure drop is restored. DIFF

MALFUNCTION 3Boral Bricks, Inc. Smyrna Plant

Page 27 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Description of Equipment: Reagent is fed by gravity th rough the feed mechanism to the dosing screw. A blower pushes material through the eductor from dosing screw to baghouse. Type of Malfunction: Failure of dosing screw reagent metering and feed
system

. Failure of blower, Fill pipe blocked Possible Causes (not complete): Malfunction of the indicator, electronics 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 free flowing reagent and that there either is or is not a problem with 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 plan t manager will be contacted immediately.

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

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

7. If non-repairable by Boral-Smyrna staff, the vendor or its repr esentatives will be

contacted to visit the site and make adequate repairs.

8. Reagent 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 w ith sufficient reagen t 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 broken and not operable, Boral-Smyrna will stop bag cleaning to preserve the reagent in the filter cake on the bags. When the repair is completed, the bags will be cleaned and the reagent feed will be increased until the normal operating pressure drop is restored. DIFF

MALFUNCTION 4Boral Bricks, Inc. Smyrna Plant

Page 28 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Description of Equipment: A tanker truck brings reagent to the site. The silo is filled pneumatically from the tanker truck. Type of Malfunction: Failure of the silo fill pipe system. Possible Causes (not complete): Malfunction of the indicator, electronics failure. Alarm Type: Visible observati on at the baghouse.

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 the tanker truck cannot fill the silo.

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 or assistant plant manager will be contacted immediately.

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

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

7. If non-repairable by Boral-Smyrna staff, the vendor or its repr esentatives will be

contacted to visit the site and make adequate repairs.

8. Reagent will be fed into the silo 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 system is properly operating such that the silo can be filled, the system is properly operating and is re ducing emissions at or above the levels indicated in the performance test. There is no malfunction as de fined in §63.2, and there are no additional steps to minimize emissions.

2. If the silo fill pipe system is broken and not operable, Boral-Smyrna will operate as normal if there is an adequate supply of reagent in the silo. If not, Boral-Smyrna will stop bag cleaning to preserve the reagent in the filter cake on the bags. When the repair is completed, the bags will be cleaned and the reagent feed will be increased until the normal operating pressure drop is restored DIFF

MALFUNCTION 5Boral Bricks, Inc. Smyrna Plant

Page 29 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Description of Equipment: The compressed air system, an integral part of the reagent 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 El ectrical 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 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 or assistant plant manager will be contacted immediately.

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

6. Boral – Smyrna has the ability to use the main plant compressor to continue to operate.

7. If non-repairable by Boral-Smyrna staff, the vendor or its repr esentatives will be

contacted to visit the site and make adequate repairs

Steps Taken to Minimize Emissions:

1. If the malfunction is just an indicator light or sensor malfunction the light or sensor will be corrected as specified above. Since the system is properly operating from a mechanical standpoint, there is no malfunc tion as defined in §63.2 and there are no additional steps to minimize emissions.

2. The air piping system allows Boral-Smyrna 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-Smyrna will continue to operate the 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.

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

MALFUNCTION 6Boral Bricks, Inc. Smyrna Plant

Page 30 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Description of Equipment: In order to operate at optimal control efficiency, the bags within the baghouse system must be systematically cleaned. Type of Malfunction: Bag Cleaning System Failure Possible Causes (not complete): Seal failures; timing circuit 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 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, th e plant manager will be contacted immediately.

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

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

7. If non-repairable by Boral-Smyrna staff, the vendor or its repr esentatives will be

contacted to visit the site and make adequate repairs

Steps Taken to Minimize Emissions:

1. If the malfunction is just an indicator light or sensor malfunction the light or sensor will be corrected as specified above. Since the system is properly operating from a mechanical standpoint, there is no 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-Smyrna will attempt to fix the failure while continuing to operate the reag ent injection baghouse system as long as all other operating parameters are within desirable operating ranges.

3. If the failure of the bag cleaning system ca nnot be corrected while operating the reagent injection baghouse system, the reagent inje ction baghouse system will go to bypass after a preset time 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. DIFF

MALFUNCTION 7Boral Bricks, Inc. Smyrna Plant

Page 31 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Description of Equipment: The reagent injection baghouse system has a fan on the outlet side of the baghous e and has numerous valves, bearings, and other mechanical and electrical components. Type of Malfunction: Mechanical & Electrical Components - Failure of motors, fans, valves, bearings, belts, etc. Possible Causes (not complete): Motor, fan, valves, bearings , etc. component failures Alarm Type: Audible and visible alarms at the 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 problem with the mechanical and electrical component s associated with the reag ent 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 or assistant plant manager will be contacted immediately.

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

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

7. If non-repairable by Boral-Smyrna staff, the vendor or its repr esentatives will be

contacted to visit the site and make adequate repairs

Steps Taken to Minimize Emissions:

1. If the malfunction is just an indicator light or sensor malfunction the light or sensor will be corrected as specified above. Since the system is properly operating from a mechanical standpoint, there is no malfunc tion as defined in §63.2 and there are no additional steps to minimize emissions.

2. If there is a failure of the mechanical and electrical components, Boral-Smyrna will attempt to fix the failure while continuing to operate the reag ent injection baghouse system as long as all other operating paramete rs are within desirabl e operating ranges.

3. Some of the failures listed in this malfunction cannot be corrected while operating the reagent injection baghouse syst em. If a mechanical and el ectrical component failure cannot be corrected while operating the reag ent injection baghouse system, the reagent injection baghouse system will be shutdow n 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. DIFF

MALFUNCTION 8Boral Bricks, Inc. Smyrna Plant

Page 32 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Description of Equipment: The reagent injection baghouse system has inlet ductwork from the kiln, outlet ductwork to the stack exit, and associated ductwork for bypass and control device gas recirculating during bypass or down time. Type of Malfunction: Ductwork Failure Possible Causes (not complete): Excessive temperature from kiln; unexpected abrasion; hidden damage under the insulation; etc. Alarm Type: Visual observations

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 ma nager or assistant plant manager will be contacted immediately.

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

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

7. If non-repairable by Boral-Smyrna staff, the vendor or its repr esentatives will be

contacted to visit the site a nd make adequate repairs.

Steps Taken to Minimize Emissions:

1. If the malfunction is just an indicator light or sensor malfunction the light or sensor will be corrected as specified above. Since the system is properly operating from a mechanical standpoint, there is no malfunc tion as defined in §63.2 and there are no additional steps to minimize emissions.

2. If there is ductwork failure, Boral-Smyrna w ill attempt to fix the failure while continuing to operate the reagent injecti on baghouse system as long as all other operating parameters are within desirable operating ranges.

3. If the failure of the ductwork cannot be corr ected while operating the reagent injection baghouse system, the reagent 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. DIFF

MALFUNCTION 9Boral Bricks, Inc. Smyrna Plant

Page 33 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Description of Equipment: Each baghouse module has inle t and outlet isol ation valves and the system has a bypass va lve to allow bypass of the

DIFF. Type of Malfunction: Damper/Damper Drives Failure Possible Causes (not complete): Compressed air; damper fa ilure; electronics 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 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, the plant manager will be contacted immediately.

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

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

7. If non-repairable by Boral-Smyrna staff, the vendor or its repr esentatives will be

contacted to visit the site a nd make adequate repairs.

Steps Taken to Minimize Emissions:

1. If the malfunction is just an indicator light or sensor malfunction the light or sensor will be corrected as specified above. Since the system is properly operating from a mechanical standpoint, there is no malfunc tion as defined in §63.2 and there are no additional steps to minimize emissions.

2. If there is damper failure, Boral-Smyrna will a ttempt to fix the failure while continuing to operate the reagent 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 reag ent injection baghouse system, the reagent 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. DIFF

MALFUNCTION 10Boral Bricks, Inc. Smyrna Plant

Page 34 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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 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 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 an electrical control failure, the plant manager or assistant plant manager will be contacted immediately.

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

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

7. If non-repairable by Boral-Smyrna staff, the vendor or its repr esentatives will be

contacted to visit the site and make adequate repairs.

Steps Taken to Minimize Emissions:

1. If the malfunction is just an indicator light or sensor malfunction the light or sensor will be corrected as specified above. All sens or or indicator malfunctions that affect compliance status will be recorded under this Malf unction No. 11.

2. If there is an electrical com ponent failure, Boral-Smyrna will attempt to fix the failure while continuing to operate th e reagent injection baghouse system as long as there is power to key operating components of the reagent injection ba ghouse and all other operating parameters are within desirable operating ranges.

3. If the electrical component failure cannot be corrected while operating the reagent injection baghouse system, the reagent injection baghouse system will be shutdown until the damper is corrected. During this phase of operation, the baghouse will be bypassed.

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

MALFUNCTION 11Boral Bricks, Inc. Smyrna Plant

Page 35 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 Description of Equipment: A rotary valve discharges used reagent from the bagfilter hopper into super sacks. Type of Malfunction: Disc harge rotary valve failure Possible Causes (not complete): Motor failure; bearing/air lock failure; electronics 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 manage r or assistant plant manager will be contacted immediately.

5. Key Boral-Smyrna 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 rotary air lock valve is not operable, reagent will be continuously injected and the baghouse will alarm as usual. If the hopper fills and the valve is not repaired, reagent injection and bag cleaning will stop until the 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. DIFF

MALFUNCTION 12Boral Bricks, Inc. Smyrna Plant

Page 36 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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: Visual Observation or Alarm

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 ma nager will be contacted immediately.

5. Key Boral-Smyrna 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-Smyrna 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. DIFF

MALFUNCTION 13Boral Bricks, Inc. Smyrna Plant

Page 37 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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 st eps listed below (from Bundy manual)

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 DIFF

MALFUNCTION 14Boral Bricks, Inc. Smyrna Plant

Page 38 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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:

1. 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.

2. Boral-Smyrna will maintain spare parts recommended by the baghouse vendor to ensure parts most likely to require replacement are available.

3. If there is an excessive pressure drop th at can damage the baghouse, Boral-Smyrna 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, th e kiln will be operated as smoothly as possible to minimize emissions during malfunction.Boral Bricks, Inc. Smyrna Plant

Page 39 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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 : Visual Observation

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:

Root Cause Steps Cleaning cycle too frequent Ad just pressure drop cleaning

Cleaning cycle based on time rather than pressure drop Adjust back-up time to longer period to ensure pressure drop is the basis for the cleaning

Power failure Once the power has returned we will increase the reagent feed by 40% to build the cake up

faster.

Exhaust fan failure Correct the exhaust problem then increase the reagent feed by 40% if our DP is below 1.0.

4. If malfunction cannot be repaired in 2 hours, notify management to evaluate whether change in kiln operation is warranted.

5. Once the incident has been repaired, follow st art-up procedures, if the system was shut

down.

Steps Taken to Minimize Emissions:

1. Increasing the reagent feed helps build the reagent cake up on the bags faster. The 40% increase builds it up as soon as possi ble without causing other problems.

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

MALFUNCTION 15Boral Bricks, Inc. Smyrna Plant

Page 40 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 3. If there is an insufficient pr essure drop that can damage the baghouse, Boral-Smyrna 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.Boral Bricks, Inc. Smyrna Plant

Page 41 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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: None- determined from visible observation

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. Depending on root cause, follow remedy steps listed in Bundy Manual.

6. If malfunction cannot be repaired in 2 hours, notify management to evaluate whether change in kiln operation is warranted.

7. Once the incident has been repa ired, follow start-up procedures.

Steps Taken to Minimize Emissions:

1. Boral-Smyrna will seek to identify whether a single baghouse module is causing the visible emissions (this would most often be the case) as soon as practicable. Then, the

exhaust will be vented th rough the remaining modules.

2. If the malfunction can only be fixed by s hutting the baghouse down, Boral-Smyrna 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. DIFF

MALFUNCTION 16Boral Bricks, Inc. Smyrna Plant

Page 42 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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: Indicator alarm at 400 o F (“High temperature”)

Critical alarm if > 425 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 450 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-Smyrna 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-Smyrna 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. DIFF

MALFUNCTION 17Boral Bricks, Inc. Smyrna Plant

Page 43 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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: Lack of Damper on a shutdown kiln , allows for cold air Type of Alarm: System alarm at 300° F

Critical alarm if < 275° F

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-Smyrna 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. DIFF

MALFUNCTION 18Boral Bricks, Inc. Smyrna Plant

Page 44 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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-Smyrna Staff

Steps Taken to Correct Problem:

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

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

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

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

5. Normally the facility will have to rese t the ID fan and the dilution fan to AUTO.

Steps Taken to Minimize Emissions:

1. After a power failure, Boral-Smyrna personnel w ill confirm that all default settings have been reset to the correct operating order as quickly as possible.

2. In most cases, the DIFF will continue to operate and since there is reagent in the system during much of the malfunction HF will continue to be removed. DIFF

MALFUNCTION 19Boral Bricks, Inc. Smyrna Plant

Page 45 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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, Inc. Smyrna Plant

Page 46 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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, Inc. Smyrna Plant

Page 47 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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 Corben Pate

Direct Phone: 771-550-0662

Kiln Supervisor/ Plant Environmental Officer: Jimmie Galbreath

770-550-4620

Regional 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. Smyrna Plant

Page 48 of 50 BORA-1_Smyrna SSMP.doc Revision 5: 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-Smyrna 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-Smyrna vary considerably, depending on whether the actions take n were consistent with the SSMP.

 If the actions taken during the malfunction were consistent with this SSMP, Boral-Smyrna 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 in cluded (§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 malf unction that occurred, and the Boral-Smyrna’s SSMP shouldBoral Bricks, Inc. Smyrna Plant

Page 49 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 include these events or actions for future ev ents. 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. Smyrna Plant

Page 50 of 50 BORA-1_Smyrna SSMP.doc Revision 5: July 2, 2007 SECTION 7.2- EXAMPLE REPORT FORMS

7.2.1 Malfunction reports (internal)

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

SSMP was followed.

7.2.2 Malfunction Log

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

7.2.3 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.

7.2.4 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

### A PPENDIX 

### A

– R ECORDS OF 

### SSM E VENTSBoral Bricks, Inc. Smryna 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. Smryna 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.Smyrna 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 Smyrna Plant

START-UP AND SHUTDOWN LOG

DATE Begin “Start-up” End “Start-up” Begin
“Shutdown” End
“Shutdown” NotesBoral Bricks, Inc. Smyrna 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

### A PPENDIX 

### B

– T ROUBLE 

### S HOOTINGSYMPTOM CAUSE REMEDY High Baghouse Pressure Drop Incorrect Pressure Reading Clean Pressure Taps

Check hoses for leaks Check diaphragm in gauge

Bag cleaning not adjusted prope rly 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 NOTE:

Boral has reproduced the following troublesh ooting table from the Bundy manual for

ease of use. It is im portant to note that NOT ALL CONDITIONS LISTED IN THE

BUNDY TABLE ARE MACT MALFUNCTIONS . The conditions that Boral has determined are most likely to create MACT Malfunction conditions are listed in the table at the beginning of this section.SYMPTOM CAUSE REMEDY

High Baghouse Pressure Drop Dust not being removed from bags Increase air pressure Condensation on bags (see below) Send bag to lab for analysis Replace bags

Excessive re-entrainment of dust Check hopper for plugging Continuously empty hopper Clean rows of bags randomly instead of sequentially

Baghouse undersized Consult supplier

Low Fan Motor Amperage/Low

Gas Volume High baghouse pressure drop

Fan and motor sheaves reversed See above

Check drawings and reverse sheaves

Duct plugged with dust Clean out duct and check duct

velocities

Damper(s) closed Check all duct dampers

System static pressure too high Measure static on both sides of fan and review with design Duct velocity too high Duct design not proper

Fan not operating per design Check fan inlet configuration and be

sure even air flow exists Check impeller for wear

Fan belts slipping Check tension and adjust Replace belts

Fan rotation incorrect Check rotation with indicator on fan or drawingsSYMPTOM CAUSE REMEDY

Dust Escaping at Source (Puffing) Low Air Volume See above

Ducts leaking Patch duct leaks so air does not bypass source

Improper duct balancing Adjust dampers in duct branches Dirty discharge Bags leaking Replace bags Plug or cap broken bags and replace

later

Improper seal at tubeshee t Check bag/cage/tubesheet

attachment

Failure in seals of joints at clean/dirty air connection Caulk or weld seams

Insufficient filter cake Allow more particulate to build on bags by cleaning less frequently

Bags too porous Send bag for permeability testing and review with supplier

Excessive Fan

Wear Fan handling too much particulate See above

Improper fan design Check application with

manufacturer

Fan speed too high Check with manufacturerSYMPTOM CAUSE REMEDY

Excessive Fan

Vibration Build-up of dust on blades Clean off and check to see if fan is handling too much particulate (see above)

Check for moisture in fan

Incorrect fan wheel for applic ation Check with manufacturer

Sheaves not balanced Have sheaves dynamically balanced

Bearings worn Replace bearings

High Compressed Air Consumption Cleaning cycle too frequent Reduce cleaning cycle frequency if possible

Pulse duration too long Reduce duration (after initial shock all other compressed air is wasted)

Pressure too high Reduce s upply pressure if possible

Diaphragm valve failure Check diaphragms and springs

Check solenoids

Reduced Compressed Air

Pressure Compressed air consumption too high See Above

Restrictions in piping Check piping

Dryer plugged Replace desiccant

Supply pipe too small Review design

Compressor not operating properly C onsult manufacturer or compressor

maintenance manualSYMPTOM CAUSE REMEDY

Premature Bag

Failure – Decomposition Bag material improper for chemical composition of gas or particulate Analyze gas and particulate and consult with supplier

Treat with neutralizer before baghouse.

Operating below acid dew point Increase gas temperature By-pass at start-up

High Bag Failure – Wearing Out Ladder vane baffles worn out Replace ladder vane baffles

Particulate loading too high Inst all mechanical collector ahead of baghouse

Cleaning cycle too frequent Reduce cleaning frequency if possible

Improper bag support on cages Consult supplier

High Bag Failure – Burning Sparks entering baghouse Install spark arrestor

Stratification of hot and cold ga sses Force turbulence in duct with

baffles

Thermocouple failed Replace and determine cause of

failure

Failure of cooling device Consult ManufacturerSYMPTOM CAUSE REMEDY

Moisture in Baghouse Insufficient pre-heating Ch eck hopper heater operation Run system with hot air only before starting process gas flow

System not purged at shut dow n Run fan for 15-20 minutes after process is shut down

Wall temperature below dew point Raise gas temperature Insulate baghouse

Cold spots through insulation Eliminate direct metal line through

insulation

Pulse air introducing wate r Check air line drains Install air dryer

Damper Valve Inoperative (Sticking) Over travel of air cylinder Adjust length of travel Replace cylinder if required

Improper lubrication Fill compressed air oiler Replace oiler

Water in air line Add dryer to air line

Check air line drains Replace desiccant in dryer Replace moisture trap

Damper Valve Fails To Operate Low air pressure See above

Solenoid failure Check power to solenoids Replace solenoids

Damper locked out Verify reason for lock out and

remove lock when safeSYMPTOM CAUSE REMEDY

Material Bridging in Hopper Moisture in baghouse See above

Material being stored in hopper Empty hopper continuously

Improper vibration Change the vibration amplitude an frequency

Ash conveyor plugged Clean ash conveyor

High Baghouse Inlet Temperature Dilution air system failure Ve rify dilution air fan speed Verify dilution air damper position

Low Baghouse Inlet Temperature Dilution air control failure Check dilution air fan speed Check dilution air damper position Low process exhaust rate or

temperature Increase process temperature or rate if possible

### A PPENDIX 

### C

– S EMI 

### A NNUAL 

### R EPORTS

### A PPENDIX 

### D

– P REVIOUS 

### V ERSIONS OF 

### SSM P LAN