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 Date 
TABLE 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 SOURCES 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 SSMP 
Revision to SSMP: 

Date of Revision Reason for Revision 

July 5, 2006 Original SMMP 

April 20, 2007 Revised Lime flow 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, clarified 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 

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SECTION 1.0- INTRODUCTION 

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

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

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

covers the Smyrna facility tunnel kilns (Kiln 1 and Kiln 2) and the reagent injection fabric filter 

(DIFF) system, which are the affected sources in the Subpart JJJJJ. 

At all times, including periods of startup, shutdown, and malfunction, Boral Bricks, Inc. (BoralSmyrna) will operate and maintain any air pollution control equipment and monitoring 

equipment that are used to comply with the standard in a manner consistent with safety and good 

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

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

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

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

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

source. 

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

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

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

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

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

when Kiln 1, Kiln 2 and the control device are being started, shutdown, and during malfunctions. 

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

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

instances have been included in this SSMP. 
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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 describes, in detail: (1) procedures for operating and 

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

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

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

(A) Ensure that, at all times, Boral-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 correct malfunctions as soon as practicable after 

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

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

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

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

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SECTION 3.0 - REGULATORY ANALYSIS 

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

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

that Boral-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 malfunction occurs at an affected process, air 

pollution control device or monitoring equipment. 

 In addition to the requirements to develop and implement a written SSMP, Boral-Smyrna 

is also required under §63.6(e)(3)(vii) to perform the following 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 that 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 Provisions define a “malfunction” as: 

Any sudden, infrequent, and not reasonably preventable failure of 

air pollution control and monitoring equipment, process 

equipment, or a process to operate in a normal or usual manner 

which causes, or has the potential to cause, the emission limitations 

in an applicable standard to be exceeded. (§63.2). 

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

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

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

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

Smyrna Plant 

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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 with the equipment manufacturer’s specifications 

and recommendations, as well as the procedures specific to Boral-Smyrna that are detailed in our 

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

Smyrna Plant 

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SECTION 4.0- AFFECTED SOURCES 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 -Kiln 1 (EU01), Kiln 2 (EU02) 

Capture/Control/Monitoring Device ID: Reagent 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 promulgation 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 injection baghouse system in order to comply with the 

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

Smyrna Plant 

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SECTION 5.0- PROCEDURES FOR STARTUP, SHUTDOWNS, & 

 MALFUNCTIONS 

This section includes a description of Boral-Smyrna standard procedures for starting Kiln 1 

(EU01), Kiln 2 (EU02), and reagent injection baghouse system, shutting down the kilns and 

reagent injection baghouse system, and for dealing with malfunctions that occur. For the 

purposes of this plan, the malfunctions include only those incidents that have the potential to 

cause an exceedance of the emission or operating limits. These situations would include: 

o A situation that causes the emissions from Kiln 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 injection baghouse system to fail, thus 

increasing emissions above the NESHAP limits. 

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

o Failure of the electronic monitoring system. 

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

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

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

visitors is always the first priority. 

To balance these, Boral follows the following general principles: 

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

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

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

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

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

to be encountered]. 

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

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

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

damaging the integrity of the cleaning process. 

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

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

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

blockages. 

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

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

shutdown procedure (i.e., “hard shutdown”) and numerous malfunction scenarios. 
Boral Bricks, Inc. 

Smyrna Plant 

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SECTION 5.1- STARTUP PROCEDURES 

The startup procedures for the kilns and reagent injection fabric filter 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 350o

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 the 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 airlock 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 350o

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- NORMAL 
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Smyrna Plant 

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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. 
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Smyrna Plant 

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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 oF. 

8) If inlet temperature does not stabilize 

above 275 oF, 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 

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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-light of burners and re-start 

push 

Steps Taken to Minimize Emissions: 

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

interruption of natural gas supply or electrical power, no new product is placed into or 

comes out of the kiln. 

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

for pushing new product into the kiln. The minimum temperature required for the fabric 

filter operation will be reached before the kiln is at a proper temperature for introduction of 

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

be continually decreasing until the pushing of new production resumes. 
Boral Bricks, Inc. 

Smyrna Plant 

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SECTION 5.2- SHUTDOWN PROCEDURES 

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

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

principles impact the procedures 

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

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

(275 oF). 

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

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

atmosphere. 

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

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

permit #3505.

5.2.1 Normal Shutdown Procedures for Two Kilns 

The normal shutdown procedures for the kiln and 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 minutes after the feeder has 

been shut off to purge the conveying line. 

3. Allow module to operate until the low 

temperature is hit. 

SHUTDOWN- NORMAL 
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Smyrna Plant 

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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 baghouse is inactive. 

9. If maintenance on a module 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 operation. Out of service 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 

temperature 
Boral Bricks, Inc. 

Smyrna Plant 

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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 baghouse is inactive. 

7. If maintenance on a module 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 kiln 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. 
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Smyrna Plant 

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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 primary 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 exhaust fan or if the malfunction is a part of 

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

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

controlled.

SHUTDOWN- EMERGENCY 
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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 and safety requirements are also met. 

Any malfunction of the baghouse initiates an alarm: 

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

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

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

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

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

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

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

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

will also lead to a bypass if they are not corrected. 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 that needs attention. 

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

following concepts: 

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

kilns and the DIFF systems are shutdown, Boral-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 malfunctions or have the ability to contact key staff to handle 

any malfunctions of the systems. 

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

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

minimized, Boral-Smyrna will:

MALFUNCTIONS- OVERVIEW 
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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 operating under normal conditions. As long as all reagent injection 

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

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

c. Boral-Smyrna will either minimize the length of the control device downtime and bypass, 

or both, to the extent practicable during any malfunction. 

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

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

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

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

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

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

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

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

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

compliance can be documented for the occurrence. 
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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 followed 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 system 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 

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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 oF 

Critical alarm if >425 o

F 

18 Low temperature in baghouse System alarm at 300 oF 

Critical alarm if < 275 oF 

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 

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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, wiring, 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 alerted 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 causing 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 properly, 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 baghouse to go to bypass to prevent damage. 

(Inlet temperature exceedances are addressed 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 affected 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 desirable ranges, the control device will be 

operated to minimize emissions. 

KILN 

MALFUNCTION 1
Boral Bricks, Inc. 

Smyrna Plant 

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4. If there are no visible emissions in accordance with Method 22, the above occurrence 

will be documented, but will not be considered 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 

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

malfunction. During such a malfunction, there would be an 

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

continue to exhaust to the control device. However with 

improper balance of air flows, there could be an improper 

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

of this system can provide an excessive amount of smoke 

Type of Malfunction: Kiln out of Balance

Possible Causes: Improper balance of airflow 

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

alarm. It will have to be discovered by observation). 

Steps Taken to Correct Problem: 

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

2. If the kiln is out of balance, the kiln fireman 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 control device as long as there is no inlet 

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

temperature exceedances are addressed later in Kiln Malfunction 3, DIFF Malfunction 

17, and DIFF Malfunction 18). 

2. For the exhaust sent to the control device, only visible emissions should be affected by an 

out of balance malfunction. The continued operation 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 operating parameters are acceptable, Boral-Smyrna 

will continue to operate the control device to minimize emissions from the kiln exhaust. 

(New plant only) 

4. If there is no back-drafting through the dryer, Boral-Smyrna will consider the balance 

problem to be malfunction if there are visible emissions as identified by Method 22 

during such episode. As long as all control device operating parameters are within 

desirable ranges, the control device will be operated to minimize emissions. (New plant 

only) 

KILNMALFUNCTION 2
Boral Bricks, Inc. 

Smyrna Plant 

Page 22 of 50 BORA-1_Smyrna SSMP.doc 

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5. If there is no back-drafting through the dryer and if there are no visible emissions in 

accordance with Method 22, the above occurrence will be documented, but will not be 

considered a malfunction as identified in §63.2 and will not be reported 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 reasons that the control device 

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

to protect equipment. 

Type of Malfunction: Kiln Malfunction that Causes a Bypass of 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 observation (or alerted by an indicator light or 

alarm) and responds immediately. 

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

electronic feedback to the computer system. 

3. The plant manager 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 procedures 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 3
Boral Bricks, Inc. 

Smyrna Plant 

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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 observation (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 flow sensor system and level indicator sensors 

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

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

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

lack of reagent in the silo. 

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

immediately. 

6. Key Boral-Smyrna personnel will contact reagent 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 problems, these will be corrected to properly 

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

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

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

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

minimize emissions. 

2. If there is no 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 1
Boral 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 observation (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 temporary bridging of the material will be 

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

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

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

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

insure that reagent flow was as continuous 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 reagent 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 problems, these will be corrected to properly 

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

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

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

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

minimize emissions. 

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

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

reagent flow was as continuous as possible in the interim. 

DIFF 

MALFUNCTION 2
Boral 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), which 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 observation (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 system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

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

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

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

repaired. 

7. If non-repairable by Boral-Smyrna staff, the vendor or its representatives 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 problems, these will be corrected to properly 

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

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

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

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

minimize emissions. 

2. If the feed mechanism is broken and not operable, Boral-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 3
Boral Bricks, Inc. 

Smyrna Plant 

Page 27 of 50 BORA-1_Smyrna SSMP.doc 

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Description of Equipment: Reagent is fed by gravity through 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 observation (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 system will be analyzed and corrected to ensure 

proper electronic feedback to the computer system. 

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

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

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

repaired. 

7. If non-repairable by Boral-Smyrna staff, the vendor or its representatives 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 problems, these will be corrected to properly 

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

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

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

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

minimize emissions. 

2. If the dosing screw is 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 4
Boral 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 observation at the baghouse. 

Steps Taken to Correct Problem: 

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

alarm) and responds immediately. 

2. Maintenance verifies that the tanker truck cannot fill the silo. 

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

proper electronic feedback to the computer system. 

4. If the feed mechanism is not operating, the plant manager 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, maintenance will work non-stop until the system is 

repaired. 

7. If non-repairable by Boral-Smyrna staff, the vendor or its representatives 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 problems, 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 reducing emissions at or above the levels 

indicated in the performance test. There is no malfunction as defined in §63.2, and there 

are no additional steps to minimize emissions. 

2. If the 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 5
Boral Bricks, Inc. 

Smyrna Plant 

Page 29 of 50 BORA-1_Smyrna SSMP.doc 

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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 Electrical Failure 

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

main production facility. 

Steps Taken to Correct Problem: 

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

alarm) and responds immediately. 

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

system. 

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

proper electronic feedback to the computer system. 

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

the plant manager 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 representatives will be 

contacted to visit the site and make adequate repairs 

Steps Taken to Minimize Emissions: 

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

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

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

additional steps to minimize emissions. 

2. The air piping system allows Boral-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 points. The LOW set point disables bag 

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

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

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

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

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

required to keep the baghouse outlet poppet valves open. 

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

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

operation, the baghouse will be bypassed. 

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

possible to minimize emissions during the malfunction. 

DIFF 

MALFUNCTION 6
Boral 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 observation (or alerted by an indicator light or 

alarm) and responds immediately. 

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

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

proper electronic feedback to the computer system. 

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

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

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

repaired. 

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

contacted to visit the site and make adequate repairs 

Steps Taken to Minimize Emissions: 

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

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

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

additional steps to minimize emissions. 

2. If there is a failure of the bag cleaning system, Boral-Smyrna will attempt 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 failure of the bag cleaning system cannot be corrected while operating the reagent 

injection baghouse system, the reagent injection 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, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction. 

DIFF 

MALFUNCTION 7
Boral 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 baghouse and has numerous valves, 

bearings, and other mechanical and electrical components. 

Type of Malfunction: Mechanical & Electrical Components - Failure of 

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

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

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

main production facility. 

Steps Taken to Correct Problem: 

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

alarm) and responds immediately. 

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

electrical components associated with the reagent injection baghouse system. 

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

proper electronic feedback to the computer system. 

4. If there are mechanical and electrical component failures, the plant manager 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, maintenance will work non-stop until the system is 

repaired. 

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

contacted to visit the site and make adequate repairs 

Steps Taken to Minimize Emissions: 

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

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

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

additional steps to minimize emissions. 

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

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

reagent injection baghouse system. If a mechanical and electrical component failure 

cannot be corrected while operating the reagent injection baghouse system, the reagent 

injection baghouse system will be shutdown until the failure is corrected. 

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

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

emissions during the malfunction. 

DIFF 

MALFUNCTION 8
Boral 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 observation (or alerted by an indicator light or 

alarm) and responds immediately. 

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

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

proper electronic feedback to the computer system. 

4. If there are ductwork failures, the plant manager 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, maintenance will work non-stop until the system is 

repaired. 

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

contacted to visit the site and make adequate repairs. 

Steps Taken to Minimize Emissions: 

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

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

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

additional steps to minimize emissions. 

2. If there is ductwork failure, Boral-Smyrna will attempt 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 failure of the ductwork cannot be corrected 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, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction. 

DIFF 

MALFUNCTION 9
Boral 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 inlet and outlet isolation valves 

and the system has a bypass valve to allow bypass of the 

DIFF. 

Type of Malfunction: Damper/Damper Drives Failure 

Possible Causes (not complete): Compressed air; damper 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 observation (or alerted by an indicator light or 

alarm) and responds immediately. 

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

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

proper electronic feedback to the computer system. 

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

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

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

repaired. 

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

contacted to visit the site and make adequate repairs. 

 

Steps Taken to Minimize Emissions: 

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

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

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

additional steps to minimize emissions. 

2. If there is damper failure, Boral-Smyrna will attempt 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 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, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction. 

 

 

DIFF 

MALFUNCTION 10
Boral 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 covered in previous sections, but 

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

outliers. 

Type of Malfunction: Electrical Controls Failure 

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

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

main production facility 

Steps Taken to Correct Problem: 

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

alarm) and responds immediately. 

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

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

proper electronic feedback to the computer system. 

4. If there is 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, maintenance will work non-stop until the system is 

repaired. 

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

contacted to visit the site and make adequate repairs. 

Steps Taken to Minimize Emissions: 

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

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

compliance status will be recorded under this Malfunction No. 11. 

2. If there is an electrical component failure, Boral-Smyrna will attempt to fix the failure 

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

power to key operating components of the reagent injection baghouse 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, the kiln will be operated as smoothly as 

possible to minimize emissions during the malfunction. 

 

 

DIFF 

MALFUNCTION 11
Boral 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: Discharge 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 observation (or alerted by an indicator light or 

alarm) and responds immediately. 

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

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

proper electronic feedback to the computer system. 

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

immediately. 

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

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

possible. 

Steps Taken to Minimize Emissions: 

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

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

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

additional steps to minimize emissions. 

2. If the 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 valve is fixed. As a last resort, the baghouse 

will be shut down and bypassed to repair the valve. 

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

possible to minimize emissions during the malfunction. 

 

 

DIFF 

MALFUNCTION 12
Boral 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 reagent injection baghouse system will 

periodically fail due to unforeseen reasons. 

Type of Malfunction: Bag Failure 

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

Alarm Type: Visual Observation or Alarm 

Steps Taken to Correct Problem: 

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

parameters) and responds immediately. 

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

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

proper electronic feedback to the computer system. 

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

5. Key Boral-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 malfunction 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 replacement, the baghouse will be bypassed and a 

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

as possible. 

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

possible to minimize emissions during the malfunction. 

DIFF 

MALFUNCTION 13
Boral 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 or 

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

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

 main production facility 

Steps Taken to Correct Problem: 

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

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

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

3. Depending on root cause, follow remedy steps listed below (from Bundy manual) 

CAUSE REMEDY 

Incorrect Pressure Reading Clean Pressure Taps 

Check hoses for leaks 

Check diaphragm in gauge 

Bag cleaning not adjusted properly Increase cleaning frequency 

Increase compressed air pressure 

Insufficient compressed air pressure Increase pressure 

Check dryer and clean if necessary 

Check piping for closed valves or 

other obstructions 

Pulse valves failed Check diaphragms 

Check solenoids 

Check PLC/pulse panels 

Cleaning timer failure Check to see if timer is indexing all 

contacts 

Check output on all terminals 

Dust not being removed from bags Increase air pressure 

Condensation on bags 

DIFF 

MALFUNCTION 14
Boral 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 indicates excessive reagent on the bags, exhaust will 

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

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

achieved during the incident. 

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 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 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 baghouse. If not, switch to bypass mode. 

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

Root Cause Steps 

Cleaning cycle too frequent Adjust 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 start-up procedures, if the system was shut 

down. 

Steps Taken to Minimize Emissions: 

1. Increasing the reagent feed helps build the reagent cake up on the bags faster. The 40% 

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

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

DIFF 

MALFUNCTION 15
Boral Bricks, Inc. 

Smyrna Plant 

Page 40 of 50 BORA-1_Smyrna SSMP.doc 

Revision 5: July 2, 2007 

3. If there is an insufficient pressure 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: Visible Emissions from Stack 

Possible Causes: Bag breakage; improper duct balancing; 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 close off one module at a time until location of 

leak can be determined. 

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

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

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

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

5. 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 repaired, 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 through the remaining modules. 

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

bypass the baghouse and will correct the problem 

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

possible to minimize emissions during the malfunction. 

DIFF 

MALFUNCTION 16
Boral 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 oF (“High temperature”) 

Critical alarm if > 425 oF (“High-high temperature”) 

Steps Taken to Correct Problem: 

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

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

2. If temperature remains below 450 o

F, continue to vent through one or more baghouse 

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

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

maintenance manual. 

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

change in kiln operation is warranted. 

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

Steps Taken to Minimize Emissions: 

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

that the Critical Alarm is not triggered. 

2. If there is an excessive temperature that can damage the baghouse, Boral-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, the kiln will be operated as smoothly as 

possible to minimize emissions during malfunction. 

 

DIFF 

MALFUNCTION 17
Boral 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 flowing to control device 

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

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

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

maintenance manual. 

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

change in kiln operation is warranted. 

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

Steps Taken to Minimize Emissions: 

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

2. If there is an insufficient temperature and can damage the baghouse, Boral-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, the kiln will be operated as smoothly as 

possible to minimize emissions during malfunction. 

DIFF 

MALFUNCTION 18
Boral 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 Automatic 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 reset the ID fan and the dilution fan to AUTO. 

Steps Taken to Minimize Emissions: 

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

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

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

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

DIFF 

MALFUNCTION 19
Boral 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 equipment is off-line or otherwise impaired. 

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

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

soon as it is practicable, for example: 

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

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

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

cannot be repaired in a timely manner. 

ACTS OF GOD
Boral Bricks, 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 equipment is off-line or otherwise impaired. 

 Notify appropriate maintenance or other responsible personnel. 

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

soon as it is practicable, for example: 

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

from equipment to power source; 

o Check source of gas; 

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

or breaks in line exist; and 

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

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

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

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

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

operate until the situation is corrected. 

LOSS OF POWER/GAS
Boral Bricks, Inc. 

Smyrna Plant 

Page 47 of 50 BORA-1_Smyrna SSMP.doc 

Revision 5: July 2, 2007 

SECTION 6.0- RESPONSIBILITIES AND POINTS OF CONTACT 

SECTION 6.1- ORGANIZATIONAL CHART 

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

email), their responsibilities, back up personnel. 

Plant Manager 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 VERSION CONTROL PROCEDURES 

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

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

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 shutdowns of the machines 

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

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

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

The types of reports that are required to be submitted by Boral-Smyrna vary considerably, 

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

 If the actions taken during the malfunction were consistent with this SSMP, Boral-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 included (§63.10(d)(5)(i)): 

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

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

Malfunction Plan; 

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

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

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

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

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

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

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

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

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

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

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

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

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

o Explanation of the circumstances of the malfunction; 

o The reasons for not following the current SSMP; and 

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

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

the particular type of malfunction that occurred, and the Boral-Smyrna’s SSMP should 
Boral 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 events. Then General Provisions also require 

((§63.6(e)(3)(viii)): 

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

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

program of corrective action to address the malfunctions; and 

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

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

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 occurs - 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/written notification required within 2 days of malfunction not 

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

included in SSMP; language to include in semiannual reports. 

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 
 

APPENDIX A – RECORDS OF SSM EVENTS 
Boral 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 answers to 1 and 2 are NO, proceed with answering 3 and 4 below. 

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

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

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

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

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

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

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

example notifications. 

Signature: ___________________ Date: _________________________ 

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

TRACKING 

NUMBER: ________ 
Boral Bricks, Inc. 

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 incorporate this malfunction (see Section 7.1) 
Boral Bricks, Inc. 

Smyrna Plant 

Incident/Malfunction Tracking Log 

Date 

Tracking 

Number 

Was the 

Incident a 

Malfunction?

If YES, was 

the SMMP 

followed? 

If SSMP not followed.... 

W

Was 2nd day 

report called 

in or faxed? 

Was 7th day 

report mailed 

Was SSMP 

modified? 

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

abcd- 
BORAL BRICK

Smyrna Plant 

START-UP AND SHUTDOWN LOG 

DATE 

Begin 

“Start-up” 

End 

“Start-up”

Begin 

“Shutdown”

End 

“Shutdown” Notes 

 
Boral Bricks, Inc. 

Smyrna Plant 

NOTIFICATION REPORT FOR MALFUNCTIONS NOT COVERED BY SSMP

Type of Malfunction: 

Date of Malfunction: 

Explanation of the circumstances of the malfunction: 

Reasons for not following the current SSMP: 

Responsible Official: Name: 

Title: 

Signature 

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

Georgia Department of Natural Resources 

Environmental Protection Division 

Air Protection Branch 

FAX: 404.363.7100 

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

Georgia Department of Natural Resources 

Environmental Protection Division 

Air Protection Branch 

4244 International Parkway, Suite 120 

Atlanta, Georgia 30354 
APPENDIX B – TROUBLE SHOOTING
SYMPTOM CAUSE REMEDY 

High Baghouse 

Pressure Drop 

Incorrect Pressure Reading Clean Pressure Taps 

Check hoses for leaks 

Check diaphragm in gauge 

 Bag cleaning not adjusted properly Increase cleaning frequency 

Increase compressed air pressure 

 Insufficient compressed air pressure Increase pressure 

Check dryer and clean if necessary 

Check piping for closed valves or 

other obstructions 

 Pulse valves failed Check diaphragms 

Check solenoids 

Check PLC/pulse panels 

 Cleaning timer failure Check to see if timer is indexing all 

contacts 

Check output on all terminals 

NOTE: 

Boral has reproduced the following troubleshooting table from the Bundy manual for 

ease of use. It is important 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 drawings 
SYMPTOM 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 tubesheet 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 manufacturer 
SYMPTOM 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 application 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 supply 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 Consult manufacturer or compressor 

maintenance manual 
SYMPTOM 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 Install 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 gasses Force turbulence in duct with 

baffles 

 Thermocouple failed Replace and determine cause of 

failure 

 Failure of cooling device Consult Manufacturer 
SYMPTOM CAUSE REMEDY 

Moisture in 

Baghouse 

Insufficient pre-heating Check hopper heater operation 

Run system with hot air only before 

starting process gas flow 

 System not purged at shut down 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 water 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 safe 
SYMPTOM 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 Verify 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 
APPENDIX C – SEMI ANNUAL REPORTS 
APPENDIX D – PREVIOUS VERSIONS OF SSM PLAN