Startup, Shutdown and Malfunction Plan 

In Accordance with Brick and Structural Clay Products 

National Emission Standard for Hazardous Air 

Pollutants 

[SSMP for Brick MACT] 

For 

BORAL BRICKS - 

Bessemer Plant 6 

DATE OF ORIGINAL PLAN: 

May 16, 2007 

REVISION DATES 

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NOTE: 

THIS DOCUMENT IS CONSIDERED 

COMPANY CONFIDENTIAL 

AND SHALL NOT BE COPIED OR CARRIED OUTSIDE 

OF BORAL WITHOUT MANAGEMENT APPROVAL 

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Prepared by: 

Susan J. Miller 

Innovar Environmental 

Cary, NC 

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Keep previous drafts of your SSMP for 5 years, including if the source is 

shut down or no longer subject to the MACT 

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1

TABLE OF CONTENTS 

1.0 INTRODUCTION

2.0 PURPOSE 

3.0 START-UP, SHUTDOWN AND MALFUNCTION PROCEDURES 

3.1 Startup Procedures 

3.2 Shutdown Procedures 

3.3 Malfunction Procedures 

4.0 RECORDKEEPING REQUIREMENTS 

5.0 REPORTING REQUIREMENTS 

APPENDIX A – FORMS 

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NOTE 

While this document includes information from the manual 

developed by the control device vendor (E.I. Tec), it is not intended 

to replace that document. 

Supplemental information, such as detailed system parameters, can 

be found in that document. 

If, however, there is a discrepancy between a discussion of how the 

control operates between this document and the E.I.Tec publication, 

this document is the most current. 

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2

1.0 INTRODUCTION 

The Brick MACT (40 CFR Part 63, subpart JJJJJ) requires that an affected source be 

operated in compliance with the emission limitations at all times. For periods of startup, 

shutdown, and malfunction, the emission limitations do not apply; however, during these 

times, the facility must comply with a facility-developed start-up, shutdown, and 

malfunction plan (SSMP). This SSMP is applicable to the kiln, the air pollution control 

device, and the monitoring equipment. 

Boral Brick (Boral) is committed to ensuring compliance with the Brick MACT and the 

requirements in the General Provisions of Part 63 (Subpart A), which apply to all 

sources subject to an industry-specific MACT (e.g., the Brick MACT). As required by 

the Brick MACT, Boral will operate and maintain any affected source and any air 

pollution control equipment and monitoring equipment that is used to meet 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. That is, Boral will either 

meet the emission standard or comply with the startup, shutdown, and malfunction plan. 

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 will comply by minimizing emissions during 

such a startup, shutdown, and malfunction event consistent with safety and good air 

pollution control practices. 

1.1 Facility/Operating Overview 

Boral’s Bessemer Plant 6 has two operating tunnel kilns and is a major source of 

hazardous air pollutants (HAP). Tunnel Kilns 1 and 2 are both “affected sources” under 

the Brick MACT and are required to meet the control requirements of the Brick MACT. 

These kilns are controlled by a dry injection fabric filter (DIFF) manufactured by E.I. Tec, 

L.P. 

The DIFF is equipped with two baghouse chambers, termed Scrubber 1 and Scrubber 2 

throughout this document. Scrubber 1 treats the exhaust stream from Kiln 1 and 

Scrubber 2 treats the exhaust from Kiln 2. The treated exhaust streams are separate 

from the point they exit their respective kilns until after they exit the baghouses. The 

streams are then combined and later exhausted through two fans, which then combine 

and discharge through one stack. Bypass stacks are located at each kiln. The cleaning 

cycle of each baghouses is based on the pressure drop across that chamber and a 

timed system to protect the integrity of the DIFF. 

The DIFF has both a fresh and a recirculated hot lime flow. Fresh lime is introduced 

independently (from the same silo) into the exhaust streams from each kiln. 

Recirculated hot lime is used in Scrubber 2. During normal operation, both the fresh 

and recirculated lime feed are used. The flow rate setting lime for each system can be 

documented through the measurement of the frequency of the auger, measured in Hz. 
3

A correlation between the Hz reading and the lime flow rate is provided in the E.I. Tec 

manual. The readings for the lime feed settings are established during performance 

tests and the setting will be documented as part of the MACT compliance described in 

Bessemer’s Operations, Maintenance and Monitoring Plan (OMMP). 

Boral is committed to running the control and all monitors to ensure ongoing emission 

reduction, while protecting both the integrity of the system (which ensures ongoing 

emission reduction) and safety. 
4

2.0 PURPOSE 

The purpose of this document is to comply with the MACT requirements related to 

developing and complying with a SSMP. The purpose of an SSMP [§63.6(e)(3)] is to 

ensure that a facility: 

 Is operated and maintained in a manner that meets the general duty clause to 

minimize emissions 

 Corrects malfunctions as soon as practicable in order to minimize HAP emissions 

to the environment. 

 Reduce reporting burdens associated with start-ups, shutdowns, and 

malfunctions. 

Regulatory Overview 

The general regulatory requirements cited below are addressed in our plan 

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

JJJJJ requires that we develop and implement a Startup, Shutdown, and 

Malfunction Plan for operations used to comply with the Brick and Structural Clay 

Products MACT. 

 Section 63.6(e)(3) of Subpart A, General Provisions, requires Boral Bessemer 

Plant 6 to describe what corrective action we will take if a malfunction occurs at an 

affected process, air pollution control or monitoring equipment. 

 In addition to the requirements to develop and implement a written plan, we are 

also required to: 

– Keep records of any malfunction event that occurs and keep records of the 

actions we took to minimize emissions during the event. 

– Submit reports if procedures we took during the event are not consistent 

with the procedures we put in the plan and excess emissions occurred. 

– Revise the Malfunction Plan if a malfunction occurs that has not been 

described here or procedures for corrective action have not been 

adequately described. 

– Update the plan if requested by EPA or the appropriate State or Local Air 

Pollution Control Authority. 

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Defining MACT Malfunctions 

Boral Bessemer Plant 6 may experience malfunction incidents. Please be 

aware that our operators may use a different definition of the term 

“malfunction” than the regulatory definition. We will be tracking each 

“incident” where a piece of equipment fails to operate as expected and will 

determine whether or not this event constitutes a malfunction under the 

MACT as part of this process. 

For the remainder of this document, we will use the term “MACT 

malfunction” to define an incident/malfunction that is considered a 

malfunction under §63.6(e)(3).

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5

3.0 START-UP, SHUTDOWN, AND MALFUNCTION PROCEDURES 

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 and 

create corrosion in the system. Venting at too high a temperature could damage 

the bags which would lead to visible and gaseous emissions. Initial start-up 

procedures can create high temperatures in the exhaust as the front of the kiln 

heats faster than later sections. [It should be noted that Boral uses bags 

appropriate for the expected temperature ranges.] 

 The exhaust must have 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 the baghouse) would damage the control, creating potential 

safety issues and potentially damaging the integrity of the cleaning process. 

 When possible during an incident/malfunction, Boral will continue to vent as 

much exhaust as possible through the chambers of the baghouse. Boral will 

ensure that doing so does not adversely impact worker safety or the integrity of 

the system. Venting through a chamber, even if there is no lime flow, will result 

in some level of emission reduction since cleaning is based primarily on pressure 

drop. If there is no lime flow, the differential pressure should not increase; 

therefore baghouse cleaning should not occur. 

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

3.1 STARTUP PROCEDURES 

This section describes the start-up procedures for the kilns and the E.I. Tec DIFF. The 

E.I. Tec DIFF was brought online while the kiln was in operation (when the temperature 

of the flue gas is in the right temperature range). 

The standard automated start-up procedure for the kiln and control device is described 

below. The same procedure is followed for each start-up of the control/kiln. However, 

some steps may be skipped if they have previously been completed. 

 1. Open all ball valves in the compressed air line of the installation. 

 2. Switch main switch on control panel to position „ON“. 

 3. Press “Reset” on control panel to clear all faults 

 4. Switch on gas fan 1 on control panel. 
6

 5. Switch on gas fan 2 on control panel. 

 6. Switch on scrubber 1 on control panel. 

 7. Switch on scrubber 2 on control panel. 

When this process has been completed the green lights “scrubber 1 on” and “scrubber 2 

on” must be illuminated. If the red light “LM fault” is on, then it is a malfunction in the 

system. The kind of fault is shown in the visualisation. Please refer to paragraph “4.3 

Faults and fault clearance” of the E.I. Tec Operating Manual. Push the “Reset”-button, 

to reset every fault, once the fault is cleared. 

Steps to Minimize Emissions 

 When automatic start-up is used, the system will not start until all error codes 

have been corrected. This ensures that the control can only operate when all 

systems are operating properly, which ensures minimized emissions. 

 In order to minimize emissions, the fresh lime metering screws will be set at or 

above the minimum level established during the performance test, as airflow 

allows, for a short period during start-up to ensure that the baghouses fill with 

lime as quickly as possible. 

3.2 SHUTDOWN PROCEDURES 

There is generally a low need for shutting down the control and/or the kiln. As stated 

previously, the kiln tends to remain in operation continuously. 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 (or a portion of the control device) 

until the exhaust reaches the low temperature set point. 

 If control device is operational, product feed into the kiln will be stopped before 

the lime feed into the DIFF is stopped (If kiln shutdown is required). 

 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 

HAPs to the atmosphere. Maintaining the integrity of the system is critical to 

quickly returning the system to operation. 

 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 Title V Operating Permit, once issued. 

The standard procedure for a shutdown of the kiln and control device is 

described below. 

Complete Shut-down only: 

 - Switch off scrubber 1 on control panel. 
7

 - Switch off scrubber 2 on control panel. 

 - Switch off gas fan 1 on control panel. 

 - Switch off gas fan 2 on control panel. 

 - Close all ball valves in the compressed air line of the installation. 

Maintenance/ Malfunction Shut-down (depending on which scrubber – 1 or 2- 

should be switched off) : 

Shutdown kiln and/or Scrubber #1: 

 - Switch off scrubber 1 on control panel. 

 - Open the hand-operated bypass damper in stack on kiln 1. 

 - Switch off gas fan on control panel (as needed for safe operation) 

 - Close the hand-operated shut-off damper at fan 1 

Shutdown kiln and/or Scrubber #2: 

 - Switch off scrubber 2 on control panel. 

 - Open the hand-operated bypass damper in stack on kiln 2. 

 - Switch off gas fan on control panel (as needed for safe operation) 

 - Close the hand-operated shut-off damper at fan 2 

Switching the DIFF to Bypass 

If bypass is determined to be warranted, follow the bypass procedure below in an effort 

to minimize shutdown and startup excess emissions. Document all incidents resulting 

in bypass on the Incident Report and Incident/Malfunction Tracking log: 

 Step 1. Go to the motor control center and turn on the Kiln Bypass Fans. They 

are located on the far wall in two large metal boxes. They are labeled as "KILN 

#1 BYPASS FAN" and "KILN #2 BYPASS FAN". [You can listen for the motor to 

engage as each is turned on.] If possible (considering safety and control 

integrity issues), wait about 10 seconds to turn the second one on after you start 

the first one. 

 Step 2. Move to the catwalk to where the 2 fans are located and verify that they 

are actually running. Make sure you see the belts in motion. 

 Step 3. Move to where the dampers are located. You must fully close and 

secure each damper in the closed position. Use the tools and gloves that will be 

left up there for the purpose of getting this done. 

 Step 4. Once the above procedures have been followed, the kiln can remain 

operating, which will eliminate start-up emissions. 
8

Steps to Minimize Emissions 

 Unless there is a concern about the safety of personnel or maintaining the 

integrity of the control, the kiln will continue to vent through the control device 

until the exhaust reaches the low temperature set point. This ensures that the 

exhaust will be cleaned as long as possible. 

 System may occasionally be set to bypass to avoid an automatic shutdown. This 

short-term by-pass avoids the potential emissions increase during an extended 

shutdown and start-up procedure. 
9

3.3 MALFUNCTION PROCEDURES 

This section describes the overall approach to identifying the cause of a malfunction 

incident, correcting it, and determining whether the incident meets the definition of a 

“MACT malfunction.” It should be noted that Boral Brick has a responsibility to assure 

worker safety and to comply with all OSHA and MSHA safety requirements. This will 

often affect the approach that must be taken to rectify a malfunction situation. Boral will 

work to minimize emissions at all times, while ensuring all other health and safety 

requirements are also met. 

Boral’s approach to minimizing emissions during a malfunction incident is to review the 

potential to minimize the two primary factors that influence overall emissions: duration 

and concentration of the emissions. 

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

of time the DIFF is offline, Boral will: 

a. Respond as quickly as possible to each ALARM (e.g., within 60 minutes of the 

first alarm). 

b. Maintain spare parts listed in the MACT Operation, Maintenance, and Monitoring 

Plan (MACT OMMP). 

c. Personnel, trained in alarm mode and response, are onsite at all times the kiln 

and control are in operation. Additional trained staff members are on-call 24 

hours per day.

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 will (for each incident) determine if it is 

possible to continue to vent through the control device, or part of the control device 

while the incident/MACT malfunction is being addressed (e.g., venting through the 

baghouse, even if lime flow has stopped; venting through one chamber while the 

other is being repaired). Operation in a “semi controlled” state is discussed in more 

detail below. 

Boral will either minimize the length of the downtime or the amount of emissions, or 

both, to the extent practicable during any MACT malfunction. It is important to note 

that switching to uncontrolled bypass for a short amount of time could actually 

minimize the total amount of emissions exhausted to the atmosphere. If the 

control were not bypassed, the control and/or kiln would need to be cooled over 

many hours (or days) and then restarted, which could result overall in more 

emissions. 

The Bessemer DIFF and kiln system has an automatic safety feature that turns off 

the natural gas to the kiln when the airflow through the kiln/scrubber system 

stops. This prevents an explosive situation within the kiln. Therefore, several 

incidents on the following page dictate that the DIFF to be switched to bypass if 
10

shutdown of the kiln is imminent. This minimizes the overall time that the control 

must be in bypass mode (e.g., through a lengthy re-start of the kiln) and protects 

the integrity of the DIFF. 

In addition, Boral has the potential to run in a “semi-controlled” state during periods 

where uncontrolled emissions are acceptable under the Brick MACT. This “semicontrolled” condition would allow exhaust, or a portion of the exhaust, to flow through 

the baghouses, where some lime caking would still exist on the bags. This allows Boral 

to minimize emissions due to the malfunction (or routine maintenance discussed in the 

OMMP). By opting for “semi- controlled” operation whenever possible, Boral continues 

to meet the General Duty clause to reduce emissions. 

The following sections include lists of specific procedures to be followed when an 

incident occurs that could potentially be considered a MACT malfunction under the Brick 

MACT. This list is based on a list of conditions that could have a direct impact on 

emissions, either immediately or if a situation is not corrected in sufficient time. It does 

not include other incidents that Boral reviews periodically to ensure that the control 

device is operating properly. Therefore, it is not identical to the list included in the 

E.I.Tec manual. 

The E.I.Tec DIFF has 2 categories of alarms: 

1. Shutdown Alarm – An alarm that is triggered by an event that puts personnel 

safety or equipment integrity in danger. 

2. Warning Alarm – An alarm that is triggered by an event that needs to be 

known by the operator but has no immediate impact on any other system 

components. Also an alarm that is triggered by an event that affects other 

components in the system but does not indicate current personnel equipment 

danger. 

A shutdown alarm will immediately cause the system to go into bypass and shutdown. 

This alarm is only triggered when either personnel are in danger or the integrity of the 

system could be compromised. Protecting the integrity of the system will ensure a more 

rapid return to normal operation of the control. In general, there is at least one warning 

alarm that would indicate problems before they would rise to the level of a shutdown 

alarm. 

Boral responds to warning and shutdown alarms immediately. As indicated in the 

following pages, steps are taken immediately to both identify the cause of the alarm and 

to assess whether the incident may be considered a MACT malfunction. 

The incidents/potential MACT malfunctions that have been identified are listed below 

and detailed on the following pages. 
11

Incident 

# 

Condition 

1 Pressure drop across baghouses too high 

2 Pressure drop across baghouse too low 

3 Lime flow too low and/or stopped (i.e., no 

“freeflowing lime” 

4 Airflow too low (could cause lime to not remain 

suspended) 

5 Visible emissions from stack 

6 High temperature in baghouse inlet 

7 Low temperature in baghouse inlet 

8 High level alarm in hopper 

9 Reduced compressed air pressure 

10 Mechanical equipment failure (to be used for key 

equipment failures before above conditions occur) 

11 Loss of power or gas 

12 Acts of God 
12

Type of Malfunction: Pressure Drop Higher Than Acceptable Range 

Possible Causes: Inefficient cleaning cycle in baghouse (e.g., timing or 

inefficient compressed air); faulty pressure indicator, reentrainment of lime; low fan motor amperage 

Type of Alarm: Warning Alarm

Steps Taken to Correct Problem: 

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

2. If it can be determined that the high pressure reading is in error or only in one 

chamber, determine if exhaust can still safely vent through one or both baghouse 

chambers. If so, continue to vent through baghouses. If not, switch one or both 

chambers to bypass mode. 

3. Depending on root cause (see Appendix A), follow remedy steps listed below. 

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

whether change in kiln operation is warranted or if other actions are warranted. 

5. Once the malfunctioning equipment has been repaired, follow start-up 

procedures. 

6. Complete all required paperwork. 

Steps Taken to Minimize Emissions: 

1. Since high pressure drop most likely indicates excessive lime on the bags, 

exhaust will continue to flow through one or both chambers of 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 will maintain spare parts recommended by E.I.Tec to ensure parts most 

likely to require replacement are available. 

INCIDENT 1- 
13

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 

Steps Taken to Correct Problem: 

1. Stop all bag cleaning (i.e., turn off time-based cleaning as backup to pressure-drop 

based cleaning) 

2. Determine if exhaust can still safely vent through one or more baghouse 

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

mode. 

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

4. Depending on root cause, follow remedy steps listed in the E.I. Tec table (See 

Appendix A) 

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

whether change in kiln operation is warranted. 

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

increase lime flow, if warranted, to re-establish lime build-up on bags. 

7. Complete all required paperwork 

Steps Taken to Minimize Emissions: 

1. Stopping bag cleaning while determining cause will ensure the build-up on the 

bags is not further reduced. 

2. Continuing to flow the exhaust through one or more chambers of the control (if 

possible) will provide some amount of emission reduction. 

INCIDENT 2- 
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Type of Malfunction: Limeflow Too Low and/or Stopped 

Possible Causes: Blockage before visual port; no lime in hopper, 

malfunctioning equipment 

Steps Taken to Correct Problem: 

1. Identify and remove blockage, if present. If blockage cannot be removed through 

initial efforts (e.g., external vibration), go to next step. 

2. Stop all bag cleaning (i.e., turn off time-based cleaning as backup to pressuredrop based cleaning) 

3. Check for lime in the hopper 

4. Determine if exhaust can still safely vent through one or more chambers of 

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

mode. 

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

whether change in kiln operation is warranted. 

6. Once the flow has been re-established, restart cleaning process. 

7. Increase lime feed to reestablish lime in system, if necessary. 

8. Complete all required paperwork 

Steps Taken to Minimize Emissions: 

1. Since there will continue to be lime build-up on the bags, exhaust will continue to 

flow through one or both baghouse chambers 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. Discontinuing bag cleaning during this incident will ensure that lime remains on 

the bags to provide the maximum amount of cleaning possible. 

INCIDENT 3
15

Type of Malfunction: Airflow Through System Too Low 

Possible Causes: Exhaust Fan Failure, Bag Blinding

Steps Taken to Correct Problem: 

1. Determine if exhaust can still safely vent through one or more chambers of the 

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

mode. 

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

3. Discontinue baghouse cleaning if lime flow has stopped. 

4. Depending on root cause, follow remedy steps listed in E.I.Tec Manual (see 

Appendix A) 

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

whether change in kiln operation is warranted. 

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

feed for limited time to re-establish build-up on filters, if necessary 

7. Complete all required paperwork 

Taken to Minimize Emissions: 

While reduced airflow may cause the system to automatically discontinue limefeed 

(to prevent lime blockages caused by insufficient flow to maintain the lime in the air 

stream), there will still be lime caked on the baghouses. Therefore, 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. 

INCIDENT 4
16

Type of Malfunction: Visible Emissions from Stack 

Possible Causes: Bag breakage; improper duct balancing; improper 

seal at tube seat; 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. If problem is limited to one chamber, continue to flow through other chamber; 

continue this flow while fixing problem, as air flow allows. 

3. If the problem is other than bag breakage, determine if exhaust can still safely 

vent through baghouse while work continues to fix the malfunctioning equipment. 

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

4. Depending on root cause, follow remedy steps listed in E.I.Tec table (included in 

Appendix A). 

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

whether change in kiln operation is warranted. 

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

7. Complete all required paperwork 

Steps Taken to Minimize Emissions: 

1. Boral will seek to identify whether a single bag or a limited number of bags is 

causing the visible emissions (this would most often be the case) as soon as 

practicable. Then, those bag(s) would be closed or blinded and the exhaust will 

be vented through the remaining modules. 

INCIDENT 5
17

Type of Malfunction: High Temperature in Baghouse Inlet 

Possible Causes: Dampers stuck on dilution vent, raw gas from Kiln 

temperature. 

Type of Alarm: Warning first; switches to shutdown if temperature 

reaches 480 oF 

Steps Taken to Correct Problem: 

1. If warning alarm, take appropriate action to safely reduce temperature. 

2. Determine if short term bypass is necessary to expedite return to normal 

operation. Bypass if warranted. 

3. If shutdown alarm, DIFF will automatically switch to shutdown to avoid damage to 

the DIFF. 

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

5. If temperature remains below 480 oF, continue to vent through baghouse, unless 

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

6. Depending on root cause, follow remedy steps listed in E.I.Tec table (reproduced 

in Appendix A). 

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

whether change in kiln operation is warranted. 

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

9. Complete all required paperwork 

Steps Taken to Minimize Emissions: 

1. System integrity maintained to expedite return to normal operation 

2. Bypass stopped as soon as it is possible to safely vent through system. 

INCIDENT 6
18

Type of Malfunction: Low Temperature in Baghouse 

Possible Causes: Raw gas temperature too low.

Steps Taken to Correct Problem: 

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

2. Verify that lime is flowing to control device. 

3. Determine if exhaust can still safely vent through one or both chambers of the 

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

mode. 

4. Depending on root cause, follow remedy steps listed in E.I.Tec table (see 

Appendix A). 

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

whether change in kiln operation is warranted. 

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

7. Complete all required paperwork 

Steps Taken to Minimize Emissions: 

1. Boral will identify root cause and, where possible, draw additional heat from Kiln 

raw gas. 

INCIDENT 7
19

Type of Malfunction: High Level Alarm in Hopper 

Possible Causes: Bridging in hopper (caused by improper air loosening, 

conveyor plugged); indicator malfunction. 

Steps Taken to Correct Problem: 

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

2. Verify that lime is flowing to control device 

3. Determine if exhaust can still safely vent through one or both chambers of 

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

mode. 

4. Depending on root cause, follow remedy steps listed in E.I. Tec Manual (see 

table in Appendix A). 

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

whether change in kiln operation is warranted. 

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

7. Complete all required paperwork 

Steps Taken to Minimize Emissions: 

1. Boral will identify which hopper is high. The waste discharge system will run 

continuously until the excess lime has been removed from the cone. Emissions 

will not have increased. 

INCIDENT 8
20

Type of Malfunction: Reduced Compressed Air Pressure 

Possible Causes: Compressed air consumption too high; restriction in 

piping; air dryer plugged; compressor not operating 

properly 

Type of Alarm: Initial warning alarm provided prior to shutdown. Shut 

down procedures initiate before air needed for orderly 

shutdown is lost. 

Steps Taken to Correct Problem: 

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

2. Determine if exhaust can still safely vent through one or both chambers of the 

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

mode. If kiln and DIFF shutdown is imminent, switch to bypass to avoid lengthy 

shutdown and startup procedure. 

3. Depending on root cause, follow remedy steps listed in E.I.Tec Manual (see 

Appendix A). 

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

whether change in kiln operation is warranted. 

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

6. Complete all required paperwork 

Steps Taken to Minimize Emissions: 

1. Boral will identify the root cause of the problem. If cause is determined to be 

compressor related, Boral will provide portable compressor to replace or 

supplement air supply. 

INCIDENT 9
21

 Type of Malfunction: Mechanical Equipment Failure 

Possible Causes: Equipment Malfunction 

Type of Alarm: Warning Alarm and/or Shutdown Alarm 

Steps Taken to Correct Problem: 

1. Ensure that the situation has become stable and the hazards have been 

cleared before proceeding further. 

2. Determine if exhaust can still safely vent through one or both chambers of the 

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

mode. If kiln and DIFF shutdown is imminent, switch to bypass to avoid 

lengthy shutdown and startup procedure. 

3. Confirm the system status and note which equipment is off-line or otherwise 

impaired. 

4. Notify appropriate maintenance or other responsible personnel. 

5. Respond to correct or repair the malfunction in a safe, efficient and timely 

manner as soon as it is practicable. 

6. Follow procedures indicated in Appendix A. 

Steps Taken to Minimize Emissions: 

1. Quick response to all alarms and availability of spare parts will enable quick 

repair of malfunctioning device. 

INCIDENT 10
22

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 utility supplier if power failure/gas loss 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. 

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

failure cannot be repaired in a timely manner. 

INCIDENT 11
23

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 Sections 5 -

8). 

 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. 

INCIDENT 12
24

4.0 RECORDKEEPING REQUIREMENTS 

We will track all start-up and shutdown events. Operating hours are defined as the time 

between the end of start-up and the beginning of shutdown. 

WHEN A POTENTIAL MALFUNCTION HAPPENS 

 For all incidents that could potentially be seen as a MACT Malfunction, an Incident 

Report Form will be completed. 

 The completed Incident Report Form should be reviewed and signed by the Shift 

Supervisor and any additional comments added. 

ACTIONS 

 Operator should notify the Shift Supervisor about the incident as soon as 

practicable. 

 If the problem cannot be corrected within a reasonable amount of time after 

detection (e.g., 4 hours), notify the Shift Supervisor. This does not mean that kiln 

operation will, or should, be affected. However, additional discussions should be 

held. 

 The operator or maintenance person on duty should collect the information needed 

to complete the Incident Report Form prior to the end of the shift or no later than 24 

hours following the malfunction and submit it to the Shift Supervisor. 

 The Kiln Supervisor should review the information, complete, and sign the Incident 

Report Form and submit a copy to the Environmental Supervisor. Retain the original 

form in the shift files for five (5) years [§63.10(b)(1)]. 

 Enter Incident into Incident/Malfunction Log (optional) 
25

5.0 REPORTING REQUIREMENTS 

What Will Be Reported to Regulatory Authority When There is a Malfunction 

 If the actions taken during the malfunction were consistent with this SSMP, we 

will state this fact in our semiannual excess emissions report (due within 60 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 Appendix B 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 Malfunction 

Plan, because the plan did not address the type of malfunction that occurred 

and/or the actions taken were not included in the current Malfunction Plan, 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 Detailed explanation of the circumstances of the malfunction; 

o The reasons for not following the current Malfunction Plan; and 

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

 If the actions taken during the malfunction were not consistent with the 

Malfunction Plan or did not address the particular type of malfunction that 

occurred, and the Boral Malfunction Plan should include these events or actions 

for future events, then the Environmental Supervisor at BORAL must also 

(§63.6(e)(3)(viii)): 

o Revise the Malfunction Plan 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 Malfunction Plan in the semiannual excess 

emissions report (January 31 and July 31 of each year). 
26

 

APPENDIX AE.I.TEC TROUBLESHOOTING GUIDE 

The following table is reproduced from the E.I. Tec manual and include approaches for 

ascertaining and correcting incidents where the control is not operating properly. It is 

reproduced in its entirety for convenience and ease of use. 

It should be noted that there are MANY items listed on this table that are not included in 

this manual because it is our determination that these events do not have the potential 

to be a “MACT Malfunction.” Many of these events could impact the efficiency of this 

control (i.e., energy efficiency), they do not have the potential to directly impact MACT 

requirements. 
27

(insert Section 4.3 here)
28

APPENDIX BEXAMPLE REPORT FORMS 
BORAL BRICK

Bessemer, AL 

INCIDENT REPORT 

MALFUNCTIONING DEVICE: ________________________ 

DATE OF INCIDENT: ______________________________ 

 

Explanation of Incident (include suspected cause- can reference Incident 

Code, if appropriate) 

Determination that incident was not a malfunction under MACT 

Is this incident a malfunction under 40 CFR, Part 63? Y / N 

 If not, why? {explain how you determined that this was not a malfunction under 

MACT- for example- emissions did not increase as a result of this incident} 

Signature: ___________________ Date: _________________________ 

FOR MACT MALFUNCTIONS ONLY (If determination has yet to be made, 

complete this information) 

Duration : (Estimated) Start 

Time: 

 End Time: 

 Duration: 

Estimate of excess emissions or parameter monitoring exceedances: 

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

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

 If the answer to both questions above is YES, skip to end of form, sign, and 

stop. List malfunction in semi-annual report. 

TRACKING 

NUMBER: ________ 
BORAL BRICK

Bessemer, AL 

INCIDENT REPORT 

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

Immediate reporting required. SEE SECTION 5 OF BORAL’s 

SSMP 

3. Action Taken to Correct the Problem

4. Actions Taken to Minimize Emissions During Problem 

5. (Optional) Measures Taken to Prevent a Reoccurrence of the Problem 

Signature: ___________________ Date: _________________________ 

If the answer to questions 1 and/or 2 above is NO, answer questions 3 through 5, 

unless incident is determined to NOT be a malfunction under the MACT: [NOTE: 

SSM Plan must be revised to incorporate this malfunction]
BORAL BRICK

Bessemer, AL 

START-UP AND SHUTDOWN LOG 

DATE 

Begin 

“Start-up” 

End 

“Start-up”

Begin 

“Shutdown” 

Were SSMP 

Procedures 

Followed? 

Notes/Reason for 

Shutdown 

 

NOTE: Log dates of changes in operating mode. “Begin Start-Up” marks time that 

shutdown ends and first process is started. “End Start-Up” is when normal operation 

begins (and MACT operating limits apply). 
BORAL Brick

Bessemer, AL 

Incident/Malfunction Tracking 

Date 

Tracking 

Number 

Was the 

Incident a 

Malfunction? 

If YES, was 

the SMMP 

followed? 

If SSMP not followed.... 

Who 

th

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

Bessemer, AL 

APPENDIX C 

LOG OF CHANGES TO SSMP 
BORAL Brick

Bessemer, AL 

Change Log for SSMP Revisions 

DATE Changes (non-editorial) Initials