Date: October 27, 2014

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 facility. Enclosure 1 is attached. A total of five companies, shown in Table 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 overview of each facility’s startup and shutdown events that occurred 

over the past 3 years (based on responses to Questions 1, 2, and 3 in the survey). Six facilities 

(two companies) identified specific startup and shutdown events. Table 3 provides a summary 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) plan. The SSM plan 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 emissions (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 plans

Belden 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 plan. b None of the Glen-Gery facilities are required to develop a SSM plan. c SSM plans 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 name

Emission 

source

Air pollution 

control 

device 

(APCD)

Facility has 

either a general 

operating or 

Title V permit

Permit 

condition for 

SS

SS 

event?

Exceed 

permit 

condition?

Was SS 

event 

covered 

by 

plan?

Actions 

taken to 

minimize 

emissions 

during the 

event

Estimates 

or measurements 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 Kiln P201 DIFF Yes, same 

permit for 6 

facilities

No – No NA – – – – –

BELD-1 Belden Plant 3 Kiln P301 DIFF Yes, same 

permit for 6 

facilities

No – No NA – – – – –

BELD-1 Belden Plant 4 Kilns P401-

420

No Yes, same 

permit for 6 

facilities

No – – NA – – – No NA

BELD-1 Belden Plant 6 Kilns P601-

603

No Yes, same

permit for 6 

facilities

No – – NA – – – No NA

BELD-1 Belden Plant 8 Kilns P801-

803

SD/ESP Yes, same 

permit for 6 

facilities

No – No NA – – – – –

BELD-1 Belden Plant 9 Kilns 

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 ensure 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 indicate that the emissions profile would not meet an emission limit 

established by the stack test data (obtained during normal operation through a scrubbed kiln) that you are collecting for MACT development.
4

Facility 

ID Site name

Emission 

source

Air pollution 

control 

device 

(APCD)

Facility has 

either a general 

operating or 

Title V permit

Permit 

condition for 

SS

SS 

event?

Exceed 

permit 

condition?

Was SS 

event 

covered 

by 

plan?

Actions 

taken to 

minimize 

emissions 

during the 

event

Estimates 

or measurements 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 Kilns EU01/02 DIFF 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

Kiln 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

– – – – – – – – – – – –

BORA13

Boral Muskogee Plant – – – – – – – – – – – –

BORA17

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)

BORA18Boral 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)

BORA19

Boral Union City Plant – – – – – – – – – – – –

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

Boral Bricks comment 2: Provided 7 SSM plans.
5

Facility 

ID Site name

Emission 

source

Air pollution 

control 

device 

(APCD)

Facility has 

either a general 

operating or 

Title V permit

Permit 

condition for 

SS

SS 

event?

Exceed 

permit 

condition?

Was SS 

event 

covered 

by 

plan?

Actions 

taken to 

minimize 

emissions 

during the 

event

Estimates 

or measurements 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 Kilns TK-1/ 

TK-2: 

Comment 1

Comment 1 Yes No – – – – – – – –

GLEN-2 Glen-Gery Caledonia 

Plant

Kilns TK-1/ 

TK-2: 

Comment 1

Comment 1 Yes No – – – – – – – –

GLEN-3 Glen-Gery Capitol 

Plant

Kiln TK-1: 

Comment 1

Comment 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 Kiln SID-113: 

Comment 1

WS Yes No – – – – – – – –

GLEN-8 Glen-Gery Marseilles 

Plant

Kilns TK-A/ 

TK-B: 

Comment 1

2 DLA Yes No – – – – – – – –

GLEN-9 Glen-Gery Mid Atlantic 

Plant

Kilns TKHarrop/TKBickley: 

Comment 1

2 DLA Yes No – – – – – – – –

GLEN10

Glen-Gery York Plant Kilns TK-1/ 

TK-2: 

Comment 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 specific for startup or shutdown events. Therefore, no startup or 

shutdown events in the past 3 years can be listed as resulting in the exceedance of any permit condition or limit.
6

Facility 

ID Site name

Emission 

source

Air pollution 

control 

device 

(APCD)

Facility has 

either a general 

operating or 

Title V permit

Permit 

condition for 

SS

SS 

event?

Exceed 

permit 

condition?

Was SS 

event 

covered 

by 

plan?

Actions 

taken to 

minimize 

emissions 

during the 

event

Estimates 

or measurements 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 that emissions during normal kiln startup or 

shutdown events can be accurately depicted by stack emission testing. Not listing an exceedance within this survey does not indicate Glen-Gery's facilities would automatically meet a standard 

based solely on stack testing data. It is our belief that certain situations 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 periods 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 control. These exceptions also allow for the option of deferring 

inspections/maintenance activities with the intention of minimizing the potential for system malfunctions. The bypass operation of any control device is by nature electromechanical and is by no 

means foolproof. Although 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 assume 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 control overall. Our existing 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 data 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)

Jenk3 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

Kilns 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 name

APCD 

maintenance 

exemption? Bypass APCD?

Bypass 

allowance/exemption 

in permit?

Covered by 

contingency plan?

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 

response.

BELD-1 Belden Plant 3 – Yes; CEMS 

monitoring

Yes No NA BIA to develop SS 

standard response.

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

standard response.

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

standard response.

BELD-1 Belden Plant 8 – Yes; duct design 

now allow 

monitoring (CEMS)

Yes No NA BIA to develop SS 

standard response.

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

standard response.

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 name

APCD 

maintenance 

exemption? Bypass APCD?

Bypass 

allowance/exemption 

in permit?

Covered by 

contingency plan?

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 name

APCD 

maintenance 

exemption? Bypass APCD?

Bypass 

allowance/exemption 

in permit?

Covered by 

contingency plan?

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 

hours per 

event

Number of 

facilities 

reporting

APCD problem, issue, or maintenance

 APCD cleanout or new packing 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

BoralSmyrna

BORA-3

BoralAugusta,

Plant 4

BORA-3

BoralAugusta,

Plant 5

BORA-5

BoralBessemer

BORA-13

BoralMuskogee

BORA-17

BoralSalisbury

BORA-18

Boral-Terre 

Hautea

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, long-term DIFF 

shutdown

x x x x x x

Shutdown procedures – normal, long-term DIFF 

shutdown, baghouse 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 system x x

Kiln Kiln out of balance x x x

Kiln Air flow too low x x x

Kiln Kiln malfunction that causes a bypass of 

the reagent injection fabric filter system

x x x
12

Procedures

BORA-1

BoralSmyrna

BORA-3

BoralAugusta,

Plant 4

BORA-3

BoralAugusta,

Plant 5

BORA-5

BoralBessemer

BORA-13

BoralMuskogee

BORA-17

BoralSalisbury

BORA-18

Boral-Terre 

Hautea

DIFF No reagent feed, failure of the silo 

reagent indicator level; run out of reagent 

unknowingly

x x x

DIFF No reagent feed, bridging 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 air system x x x

DIFF Reduced compressed air pressure x x x

DIFF Bag cleaning system failures x x x

DIFF Mechanical & electrical components -

failure of motors, fans, valves, bearings, 

belts, etc.

x x x x x x

DIFF Ductwork failure x x x

DIFF Damper/damper drives failure x x x

DIFF Electrical controls failure x x x

DIFF Discharge rotary valve failure x x x

DIFF High level alarm in hopper x x

DIFF Bag failure x x x

DIFF Pressure drop higher than acceptable 

range

x x x x x x
13

Procedures

BORA-1

BoralSmyrna

BORA-3

BoralAugusta,

Plant 4

BORA-3

BoralAugusta,

Plant 5

BORA-5

BoralBessemer

BORA-13

BoralMuskogee

BORA-17

BoralSalisbury

BORA-18

Boral-Terre 

Hautea

DIFF Pressure drop across baghouse lower 

than acceptable range

x x x x x x

DIFF Visible emissions from stack x x x x x x

DIFF High temperature in baghouse x x x x x x

DIFF Low temperature in baghouse x x x x x x

DIFF Failure of automatic resets following a 

power outage

x x x x

Acts of God x x x x x x x

Loss of power/gas x x x x x x x

a The SSM plan for BORA-18, Boral-Terre Haute facility, was missing several of the malfunction incidents pages that describe each malfunction and the 

procedures to follow for correcting.