### Date: October 27

, 201 4

To: Jeff Telander, EPA/OAQPS/SPPD

From: Karen S. Schaffner, RTI International

Subject: Summary of Startup, Shutdown, and Malfunction Data for Brick and Structural Clay Products Industry

This memorandum presents information submitted by facilities in response to the Clean Air Act section 114 survey sent by the U.S. Environmental Protection Agency (EPA) to select companies in the brick and structural clay products (BSCP) industry on June 16, 2010. In

Enclosure 1 of the survey letter, EPA requested facility information on the startup and shutdown
(SS) events that resulted in exceedances of permit conditions at an affected source or portion of

an affected f acility. Enclosure 1 is attached. A total of five companies, shown in T able 1

, provided responses for 26 facilities. Facilities provided either a short narrative response to the questions or provided information in table format.

Table 2 provides an over view of each facility’s startup and shutdown events that occurred over the past 3 years ( based on responses to Q uestions 1, 2, and 3 in the survey ). Six facilities (two companies) identified specific startup and shutdown events. Table 3 provides a summar y of the types of startup and shutdown events at these facilities over the 3

- year period 2008 through 2010. Seven facilities (one company) provided a copy or partial copy of their startup, shutdown,
and malfunction ( SSM ) p lan. The SSM p lan procedures for startup and shutdown and for malfunctions are provided for the seven facilities in Table 4 . For some questions, facilities did not appear to provide a response, and these are shown as dashed lines in the tables (i.e

., “

– ” ).

In the narratives and table responses received, facilities tended to combine or intertwine startup and shutdown with bypass issues.

While EPA requested estimates or measurements of emissions during startup and shutdown, facilities did not have estimates of startup and shutdown emiss ions (Question 2.G). Two of the facilities attempted to anecdotally characterize the emissions profile during startup
and shutdown events (Boral Bricks and Jenkins Bricks) for Question 2.H. None of the facilities had performance test data for startup and shutdown events (Question 2.I).

### 2 Table 1. Companies that Provided SSM Responses

Company No. of facilities No. of SSM p lan s

Beld e n Brick Company 1 ( 6 plants) Not required a

Boral Bricks 8 7

Glen

- Gery Corporation 9 Not required b

Interstate Brick 1 0

Jenkins Brick 2 Not required c

a The Title V permit for Belden Brick facilities does not distinguish between normal operation and periods of startup

and shutdown. None of the Belden facilities are required to develop a SSM p lan.

b None of the Glen

- Gery facilities are required to develop a SSM p lan.

c SSM p lans are not required for Jenkins Brick facilities.

### 3 Table 2 . Summary of Information Provided to Enclosure 1 Information Request for Startup and Shutdown Events (Part 1)

Facility

ID Site n ame Emission

source Air pollution

control

device ( APCD ) Facility has either a general

operating or Title V permit Permit

c ondi

tion for

SS SS

event? Exceed permit

condi

tion? Was SS

event

covered by plan? Actions

taken to

mini mize

emissions during the

event Estimates

or measure

ments of

emissions during the

event Was the

emissions

profile

different during SS from

normal operation

conditions? Stack testing during

SS Monitoring data, control
system parameter monitoring,

collected during each period

**Belden Brick ( 1 facility,**  **6 plants**  **)**

BELD

- 1 Belden Plant 2 K iln P201 DIFF Yes, same permit for 6

facilities No

– No NA

– – – – –

BELD

- 1 Belden Plant 3 K iln P301 DIFF Yes, same permit for 6

facilities No

– No NA

– – – – –

BELD

- 1 Belden Plant 4 Kiln s P401

- 420 No Yes, same permit for 6

facilities No

– – NA

– – – No NA

BELD

- 1 Belden Plant 6 Kiln s P601

- 603 No Yes, same permit for 6

facilities No

– – NA

– – – No NA

BELD

- 1 Belden Plant 8 Kiln s P801

- 803 SD/ESP Yes, same permit for 6

facilities No

– No NA

– – – – –

BELD

- 1 Belden Plant 9 Kiln s P101/102 No Yes, same permit for 6

facilities No

– – NA

– – – No NA

Belden Brick comment 1: Although there are no permit exceedances to report, it does not mean that we would expect to meet a maximum achievable control technology ( MACT )

- imposed permit emission limit during these occurrences. We have reported to Ohio EPA specific hours where we would have exceeded the vacated MACT standards at Plant 2 and Plant 3. These are not true permit exceedances.

Belden Brick comment 2: Emissions bypass scrubbers during startup, shutdown ( and malfunction, and maintenance ) to ensur e efficient operation of both kiln and scrubber. Sending emissions through bypass is only done to maintain efficiency and prolong the life of our control devices, which results in the greatest overall reduction of emissions over time. Bypass periods are documented and reported to Ohio EPA per permit conditions. The fact that emissions are not scrubbed while in bypass would in dicate that the emissions profile would not meet an emission limit established by the stack test data (obtained during normal opera tion through a scrubbed kiln) that you are collecting for MACT development.

### 4 Facility

ID Site n ame Emission

source Air pollution

control

device ( APCD ) Facility has either a general

operating or Title V permit Permit

c ondi

tion for

SS SS

event? Exceed permit

condi

tion? Was SS

event

covered by plan? Actions

taken to

mini mize

emissions during the

event Estimates

or measure

ments of

emissions during the

event Was the

emissions

profile

different during SS from

normal operation

conditions? Stack testing during

SS Monitoring data, control
system parameter monitoring,

collected during each period

**Boral Bricks (8 facilities)**

BORA

- 1 Boral Atlanta Plant Kiln s EU01/02 D I FF Yes Yes Yes Yes Yes, all

but 1

event Shut down

asap; followed SSM plan No Yes (see details in facility response) No Yes (not provided)

BORA

- 3 Boral Augusta Plants
3,4,5 K iln EU05 2 DIFF Yes Yes Yes Yes Yes Followed SSM plan No Yes (for some); NA (for some) (see details in facility response) No Yes (not provided)

BORA

- 5 Boral Bessemer Plant

6 Kilns

EU003/004 DIFF Yes Yes Yes Yes Yes Followed SSM plan No Yes (see details in facility response) No Yes (not provided)

BORA

- 7 Boral Henderson Facility – – – – – – – – – – – –

BORA

13 Boral Muskogee Plant

– – – – – – – – – – – –

BORA

17 Boral Salisbury Plant Kiln BK6 DIFF Yes Yes Yes Yes Yes Followed SSM plan No Yes (see details in facility response) No Yes (not provided)

BORA

18 Boral Terre Haute

Plant Kiln EU02 DIFF Yes Yes Yes Yes (possibly) Yes Followed SSM plan No Yes (see details

in facility response) No Yes (not provided)

BORA

19 Boral Union City Plant

– – – – – – – – – – – –

Boral Bricks comment 1: Data are for 2008 through 2010.

Boral Bricks comment 2 : Provided 7 SSM p lans.

### 5 Facility

ID Site n ame Emission

source Air pollution

control

device ( APCD ) Facility has either a general

operating or Title V permit Permit

c ondi

tion for

SS SS

event? Exceed permit

condi

tion? Was SS

event

covered by plan? Actions

taken to

mini mize

emissions during the

event Estimates

or measure

ments of

emissions during the

event Was the

emissions

profile

different during SS from

normal operation

conditions? Stack testing during

SS Monitoring data, control
system parameter monitoring,

collected during each period

**Glen**

**- Gery (9 facilities)** 

GLEN

- 1 Glen

- Gery Bigler Plant Kiln s TK

- 1/

TK

- 2 : C omment 1 C omment 1 Yes No

– – – – – – – –

GLEN

- 2 Glen

- Gery Caledonia

Plant Kiln s TK

- 1/

TK

- 2 : C omment 1 C omment 1 Yes No

– – – – – – – –

GLEN

- 3 Glen

- Gery Capitol

Plant K iln TK

- 1 : C omment 1 C omment 1 Yes No

– – – – – – – –

GLEN

- 4 Glen

- Gery Iberia Plant Kiln TK

- 1 : Comment 1 DLA Yes No

– – – – – – – –

GLEN

- 5 Glen

- Gery Redfield

Plant Kiln TK

- 1 : Comment 1 Comment 1 Yes No

– – – – – – – –

GLEN

- 6 Glen

- Gery Hanley K iln SID

- 113 : C omment 1 WS Yes No

– – – – – – – –

GLEN

- 8 Glen

- Gery Marseilles

Plant K iln s TK

- A/

TK

- B : C omment 1 2 DLA Yes No

– – – – – – – –

GLEN

- 9 Glen

- Gery Mid Atlantic

Plant Kiln s TK

Harrop/TK

Bickley : C omment 1 2 DLA Yes No

– – – – – – – –

GLEN

10 Glen

- Gery York Plant Kiln s TK

- 1/

TK

- 2 : C omment 1 DLA / none Yes No

– – – – – – – –

Glen

- Gery comment 1: Glen

- Gery operates dry limestone adsorbers ( DLA ) at 4 of its 9 facilities, as well as a wet scrubber ( WS ) at its Summerville, PA facility.

Glen

- Gery comment 2: None of the individual title V permits for the facilities include any permit conditions or applicable limits spec ific for startup or shutdown events. Therefore, no startup or shutdown events in the past 3 years can be listed as resulting in t he exceedance of any permit condition or limit.

### 6 Facility

ID Site n ame Emission

source Air pollution

control

device ( APCD ) Facility has either a general

operating or Title V permit Permit

c ondi

tion for

SS SS

event? Exceed permit

condi

tion? Was SS

event

covered by plan? Actions

taken to

mini mize

emissions during the

event Estimates

or measure

ments of

emissions during the

event Was the

emissions

profile

different during SS from

normal operation

conditions? Stack testing during

SS Monitoring data, control
system parameter monitoring,

collected during each period

Glen

- Gery comment 3: Glen

- Gery would like to add that just because no limits or conditions exist within the existing operating permits does not imply t hat emissions during normal kiln startup or

shutdown ev ents can be accurately depicted by stack emission testing. Not listing an exceedance within this survey does not indicate Gl en

- Gery's facilities would automatically meet a standard based solely on stack testing data. It is our belief that certain situati ons and events during the normal operation of a brick manufacturing facility exist where stack test emission data would not accurately represent kiln emissions all of the time.

Glen

- Gery comment 4: Since brick kilns operate continuously for extensive per iods of time between shutdowns (i.e., often several years), routine maintenance helps to ensure that the control device is operating properly and will continue to operate in a manner that will achieve the greatest amount of emission contr ol. These exceptio ns also allow for the option of deferring inspections/maintenance activities with the intention of minimizing the potential for system malfunctions. The bypass operati on of any control device is by nature electromechanical and is by no means foolproof. Alt hough routine preventive maintenance is conducted on these devices, malfunctions of these devices as well as other functions of the control device do occur. For instance, power outages occur frequently and can cause the control device to automatically assu me a bypass condition to maintain the integrity and safety of the device. Therefore, bypassing the control device for certain occurrences during normal operating conditions is a realistic requirement to ensure efficient emission con trol overall. Our existi ng permits do not apply specific limits to emissions during these particular events. And, since the kilns are not controlled during the time of such events, we would expect that emissions during those times would not meet limits established by stack

test d ata obtained from a control device that is operating as expected.

**Interstate Brick (1 facility)**

154 Interstate Brick West

Jordan UT Line 3 Kiln PABCO

- 3 ( WS ) Yes No Yes No

– – – – – –

154 Interstate Brick West

Jordan UT Line 4 Kiln PABCO

- 4 ( WS ) Yes No Yes No

– – – – – –

Interstate Brick comment 1: Other than routine maintenance SS, the facility has had no SS events during the past 3 years.

**Jenkins Brick (2 facilities)**

J enk3 Jenkins Brick Jordan

Plant Kiln TK

- 1 DIFF

– – Yes No No See details No Yes (see details in facility response) None Yes (not provided) (see details)

36 Jenkins Brick Montgomery Plant Kiln s TK1 /

TK2 DIFF

– – Yes No No See details No Yes (see details in facility response) None Yes (not provided) (see details)

Note: The dash line "

– " indicates that the facility appears to not have addressed or responded to the question.

### 7 Table 2 . Summary of Information Provided to Enclosure 1 Information Request for Startup and Shutdown Events ( Part 2)

Facility

ID Site n ame APCD

m aintenance exemption? Bypass APCD? Bypass allowance/exemption in permit? Covered by contingency p lan? If yes, provided? Recommended SS

standard Comment

**Belden Brick ( 1 facility, 6 plants**  **)**

BELD

- 1 Belden Plant 2

– Yes; continuous

emissions monitoring system ( CEMS ) monitoring Yes No NA Brick Industry Association ( BIA ) to develop SS standard

re s ponse.

BELD

- 1 Belden Plant 3

– Yes; CEMS monitoring Yes No NA BIA to develop SS

standard re s ponse.

BELD

- 1 Belden Plant 4 NA NA NA No NA BIA to develop SS

standard re s ponse.

BELD

- 1 Belden Plant 6 NA NA NA No NA BIA to develop SS

standard re s ponse.

BELD

- 1 Belden Plant 8

– Yes; duct design

now allow monitoring (CEMS) Yes No NA BIA to develop SS

standard re s ponse.

BELD

- 1 Belden Plant 9 NA NA NA No NA BIA to develop SS

standard re s ponse.
**Boral Bricks (8 facilities)**

BORA

- 1 Boral Atlanta Plant

– Yes

– Yes Yes To be discussed at

later date.

BORA

- 3 Boral Augusta Plants 3,4,5

– Yes

– Yes Yes To be discussed at

later date.

BORA

- 5 Boral Bessemer Plant 6

– Yes (also states "bypass prohibited") a No Yes Yes To be discussed at

later date.

BORA

- 7 Boral Henderson Facility

– – – No (not covered under MACT) NA To be discussed at

later date.

BORA

- 13 Boral Muskogee Plant

– – – Yes (originally but not currently required or maintained) Yes (original/not current plan) To be discussed at

later date.

### 8 Facility

ID Site n ame APCD

m aintenance exemption? Bypass APCD? Bypass allowance/exemption in permit? Covered by contingency p lan? If yes, provided? Recommended SS

standard Comment

BORA

- 17 Boral Salisbury Plant

– Yes

– Yes Yes To be discussed at

later date.

BORA

- 18 Boral Terre Haute Plant Yes (123 hours) Yes

– Yes Yes To be discussed at

later date.

BORA

- 19 Boral Union City Plant

– – – No (synthetic area source) NA To be discussed at

later date.

**Glen**

**- Gery (9 facilities)** 

GLEN

- 1 Glen

- Gery Bigler Plant Yes b Yes Yes; 4% No NA BIA to provide summer
2011.

GLEN

- 2 Glen

- Gery Caledonia Plant

– – – No NA BIA to provide summer

2011.

GLEN

- 3 Glen

- Gery Capitol Plant

– – – No NA BIA to provide summer

2011.

GLEN

- 4 Glen

- Gery Iberia Plant

– – – No NA BIA to provide summer

2011.

GLEN

- 5 Glen

- Gery Redfield Plant

– – – No NA BIA to provide summer

2011.

GLEN

- 6 Glen

- Gery Hanley Yes Yes Yes; 4% for DLA; 72 hours per year per consecutive 12

- month

for WS No NA BIA to provide summer

2011.

GLEN

- 8 Glen

- Gery Marseilles Plant

– – – No NA BIA to provide summer
2011.

GLEN

- 9 Glen

- Gery Mid Atlantic Plant Yes Yes Yes; 4% No NA BIA to provide summer

2011.

GLEN

- 10 Glen

- Gery York Plant Yes Yes Yes; 4% No NA BIA to provide summer

2011.

**Interstate Brick (1 facility)**

154 Interstate Brick West Jordan UT Yes; 2% Yes

– No

– – SS are for

routine

maintenance.

### 9 Facility

ID Site n ame APCD

m aintenance exemption? Bypass APCD? Bypass allowance/exemption in permit? Covered by contingency p lan? If yes, provided? Recommended SS

standard Comment

154 Interstate Brick West Jordan UT Yes; 2% Yes

– No

– – SS are for

routine

maintenance.

**Jenkins Brick (2 facilities)**

Jenk3 Jenkins Brick Jordan Plant

– – – No

– –

36 Jenkins Brick Montgomery Plant

– – – No

– –

Note: The dash line "

– " indicates that the facility appears to not have addressed or responded to the question.

a The facility's permit prohibits bypass of the APCD

. b Interpreted the Glen

- Gery letter to mean "Pennsylvania" plants, but not those in other states.

### 10 Table 3. Summary of Startup and Shutdown Events at BSCP Facilities from 2008 through

2010

Startup or shutdown event category Number

of events Total duration of event, hour Average

hour s per

event Number of

facilities reporting

APCD problem, issue, or maintenance

APCD cleanout or n ew p acking 56 205 3.7 1

Lime silo or lime feed issue 13 40.8 3.1 2

Compressor 3 4.3 1.4 1

Blockage in waste feed line 2 23.0 11.5 1

High differential pressure 5 119.4 23.9 1

Low pressure 4 6.3 1.6 1

High temperature 2 25.7 12.8 2

Thermocouple and pressure sensors 7 37.0 5.3 3

Programming or PLC issue 4 52.4 13.1 3

Lightning strike 2 7.3 3.6 2

Total 98 NA NA NA

### 11 Table 4. Summary of Startup, Shutdown, and Malfunction Procedures

Procedures BORA

- 1

Boral

Smyrna BORA

- 3

Boral

Augusta

,

Plant 4 BORA

- 3

Boral

Augusta

,

Plant 5 BORA

- 5

Boral

Bessemer BORA

- 13

Boral

Muskogee BORA

- 17

Boral

Salisbury BORA

- 18

Boral

- Terre

Haute a

**Startup and Shutdown Procedures**

Startup procedures

– both kilns x x
Startup procedures

– one kiln x x
Startup procedures

– hot startup (or startup after short stoppage) x x x x

Startup procedures

– cold startup x x
Startup procedures

– cold kiln, cold control x x x x
Startup procedures

– hot kiln, cold control x x x x
Shutdown procedures

– normal, two kilns x x
Shutdown procedures

– normal, kiln /one kiln x x x x
Shutdown procedures

– normal, (minor or short

term ) dry sorbent injection/fabric filter ( DIFF ) x x x x x

Shutdown procedures

– normal, l ong

- term DIFF

shutdown x x x x x x

Shutdown procedures

– n ormal, long

- term DIFF
shutdown, b aghouse entry x

Shutdown procedures

– general, kiln and DIFF x
Shutdown procedures

– switching DIFF to bypass x
Shutdown procedures

– maintenance/malfunction x x x
Shutdown procedures

– emergency x x x x

**Malfunction Procedures**

Kiln Flashing s ystem x x

Kiln Kiln out of b alance x x x

Kiln Air flow too low x x x

Kiln Kiln m alfunction that causes a b ypass of

the reagent i njection fabric f ilter s ystem x x x

### 12 Procedures BORA

- 1

Boral

Smyrna BORA

- 3

Boral

Augusta

,

Plant 4 BORA

- 3

Boral

Augusta

,

Plant 5 BORA

- 5

Boral

Bessemer BORA

- 13

Boral

Muskogee BORA

- 17

Boral

Salisbury BORA

- 18

Boral

- Terre

Haute a

DIFF No r eagent f eed, failure of the silo reagent indicator level; run out of reagent unknowingly x x x

DIFF No r eagent f eed, b ridging of reagent

within the silo x x x

DIFF Lime flow too low and/or stopped x x x

DIFF Failure of fresh reagent silo feed mechanism that feeds dosing screw x x x

DIFF Failure of dosing screw reagent metering and feed system. x x x

DIFF Failure of reagent fill pipe feed x x

DIFF Blockage at exit of fresh lime screw where lime is injected into the main duct x

DIFF Failure of agitator screw x

DIFF Failure of rotary valve under the

recirculation screw x

DIFF Failure of compressed a ir s ystem x x x

DIFF Reduced c ompressed a ir p ressure x x x

DIFF Bag cleaning system f ailure s x x x

DIFF Mechanical & e lectrical c omponents

- f ailure of motors, fans, valves, bearings,
belts, etc. x x x x x x

DIFF Ductwork f ailure x x x

DIFF Damper/damper drives f ailure x x x

DIFF Electrical controls f ailure x x x

DIFF Discharge rotary valve failure x x x

DIFF High l evel a larm in h opper x x

DIFF Bag f ailure x x x

DIFF Pressure d rop h igher than a cceptable

r ange x x x x x x

### 13 Procedures BORA

- 1

Boral

Smyrna BORA

- 3

Boral

Augusta

,

Plant 4 BORA

- 3

Boral

Augusta

,

Plant 5 BORA

- 5

Boral

Bessemer BORA

- 13

Boral

Muskogee BORA

- 17

Boral

Salisbury BORA

- 18

Boral

- Terre

Haute a

DIFF Pressure d rop a cross b aghouse l ower than a cceptable r ange x x x x x x

DIFF Visible e missions from s tack x x x x x x

DIFF High t emperature in b aghouse x x x x x x

DIFF Low temperature in b aghouse x x x x x x

DIFF Failure of automatic r esets following a
power outage x x x x

Acts of God x x x x x x x
Loss of power/g as x x x x x x x

a The SSM p lan for BORA

- 18, Boral

- Terre Haute f acility

, was missing several of the malfunction incidents pages that describe each malfunction and the

procedures to follow for correcting.