## 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 fo r 5 years, including if the source is shut down or no longer subject to the MACT

********************************** ******************************* ************************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 ve ndor (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 docum ent and the E.I.Tec publication,

this document is the most current.

********************************** ************************** ********************2 1.0 INTRODUCTION

The Brick MACT (40 CFR Part 63, subpart JJJJJ) requires that an affected source be operated in compliance with the emi ssion limitations at all times. For periods of startup, shutdown, and malfunction, t he emission limitations do not apply; however, during these times, the facility must comply with a facility-developed st art-up, shutdown, and malfunction plan (SSMP). This SSMP is applic able to the kiln, the air pollution control device, and the moni toring equipment.

Boral Brick (Boral) is committed to ensur ing 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 equipm ent 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 re levant standards. That is, Boral will either

meet the emission standard or co mply with the startup, shut down, 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 malf unction, 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 operati ng 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 fabr ic filter (DIFF) manufactured by E.I. Tec,

L.P.

The DIFF is equipped with two baghouse cham bers, termed Scrubber 1 and Scrubber 2 throughout this document. Scrubber 1 treat s the exhaust stream from Kiln 1 and

Scrubber 2 treats the ex haust from Kiln 2. The treat ed 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 exhaust ed 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 measur ement of the frequency of t he 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 t he lime feed settings are es tablished during performance tests and the setting will be documented as part of the MACT compliance described in Bessemer’s Operations, Maint enance and Monitoring Plan (OMMP).

Boral is committed to running the control and all monitors to ensure ongoing emission reduction, while protecting both the integrit y of the system (which ensures ongoing emission reduction) and safety.4 2.0 PURPOSE

The purpose of this document is to comp ly 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 t hat meets the general duty clause to

minimize emissions

 Corrects malfunctions as soon as practic able in order to minimize HAP emissions

to the environment.

 Reduce reporting burdens associat ed 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 impl ement a Startup, Shutdown, and Malfunction Plan for operations used to co mply 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 requirem ents to develop and implemen t 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.

********************************** ******************************* ******************** Defining MACT Malfunctions Boral Bessemer Plant 6 may experienc e malfunction incidents. Please be aware that our operators may use a different def inition of the term “malfunction” than the regul atory 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 docum ent, we will use the term “MACT

malfunction” to define an incident/m alfunction that is considered a malfunction under §63.6(e)(3).

********************************** ************************** ***********************5 3.0 START-UP, SHUTDOWN, AND MALFUNCTION PROCEDURES

In general, the focus of our procedures is to protect both the inte grity of the control system and reduce the emissions to the atmo sphere. Boral believes that both are critical to ensuring the long-term emission re duction ability of the system. In addition, the safety of plant personnel and visi tors 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 syst em and cause the lime to solidify and create corrosion in the system. Venting at too high a temper ature could damage the bags which would lead to visible and gaseous emissions. Initial start-up procedures can create high temp eratures 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 expect ed temperature ranges.]

 The exhaust must have a clear path t hough 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 cl eaning process.

 When possible during an incident/malfunc tion, Boral will continue to vent as much exhaust as possible through t he chambers of the baghouse. Boral will ensure that doing so does not adversely impac t 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 sinc e cleaning is based primarily on pressure drop. If there is no lime flow, the diffe rential 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 st art-up procedures for the kiln s and the E.I. Tec DIFF. The E.I. Tec DIFF was brought online while the k iln was in operation (when the temperature of the flue gas is in t he 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 cont rol/kiln. However, some steps may be skipped if they have previously been completed

.

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

2. Switch main switch on c ontrol 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 gr een lights “scrubber 1 on” and “scrubber 2

on” must be illuminated. If the red light “LM fault” is on, th en it is a malfunction in the system. The kind of fault is shown in the vi sualisation. 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 syst em will not start until all error codes

have been corrected. This ens ures 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 duri ng 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 operat ion 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 dev ice (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 fo r routine maintenance, the time will be documented as being part of the time allowed under the Routine Maintenance Bypass Allowance in Boral’s Titl e 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 comp ressed air line of the installation.

Maintenance/ Malfunction Shut-down (d epending 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 dam per 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 dam per 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, follo w the bypass procedure below in an effort to minimize shutdown and startup excess emi ssions. Document all incidents resulting in bypass on the Incident Report and In cident/Malfunction Tracking log:

 Step 1. Go to the moto r control center and turn on the Kiln Bypass Fans. They are located on the far wall in two large me tal 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 possi ble (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 t he 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 ar e 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 hav e been followed, the kiln can remain operating, which will elim inate start-up emissions.8 Steps to Minimize Emissions

 Unless there is a concern about the sa fety 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 temperatur e set point. This ensures that the exhaust will be cleaned as long as possible.

 System may occasionally be set to bypa ss to avoid an automatic shutdown. This short-term by-pass avoids the potential emissions in crease 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 det ermining whether the incident meets the definition of a

“MACT malfunction.” It shoul d be noted that Boral Brick has a responsibility to assure worker safety and to comply with all OSHA and MSHA safety require ments. This will often affect the approach that must be taken to rectify a malfunction si tuation. 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 du ring a malfunction incident is to review the potential to minimize the two primary factor s that influence overa ll 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 AL ARM (e.g., within 60 minutes of the first alarm). b. Maintain spare parts list ed in the MACT Operation, Maintenance, and Monitoring Plan (MACT OMMP).

c. Personnel, trained in alarm mode and respon se, 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 (f or each incident) determine if it is possible to continue to vent through the c ontrol 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). Oper ation in a “semi controlled” state is discussed in more

detail below.

Boral will either minimize t he length of the downt ime or the amount of emissions, or both, to the extent practic able during any MACT malfunction. It is important to note that switching to uncontrolled bypass fo r 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 situati on within the kiln. Therefore, several incidents on the following page dictate that the DIFF to be switched to bypass if10 shutdown of the kiln is im minent. This minimi zes the overall time that the control must be in bypass mode (e.g., through a le ngthy 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 acceptabl e 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 ma intenance 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 s pecific procedures to be followed when an incident occurs that could potentially be co nsidered a MACT malfunction under the Brick

MACT. This list is based on a list of c onditions 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 incid ents that Boral reviews periodica lly to ensure that the control device is operating properly. Therefore, it is not identic al 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 i mmediate impact on any other system components. Also an alarm that is tri ggered 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 pers onnel 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 contro l. In general, there is at least one warning alarm that would indicate pr oblems before they would rise to the level of a shutdown

alarm.

Boral responds to warning and shutdown ala rms immediately. As indicated in the following pages, steps are taken immediately to both identify the ca use of the alarm and

to assess whether the incident ma y 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 God12 Type of Malfunction: 

### Pressure Drop Higher Than Acceptable Range

Possible Causes : Inefficient cleaning cycle in baghouse (e.g., timing or inefficient compressed air); faul ty 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 sa fely vent through one or both baghouse chambers. If so, continue to vent th rough baghouses. If not, switch one or both chambers to bypass mode. 3. Depending on root cause (s ee 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 warrant ed or if other actions are warranted. 5. Once the malfunctioning equipm ent has been repaired, follow start-up procedures. 6. Complete all required paperwork.

Steps Taken to Minimize Emissions:

1. Since high pressure drop most likel y 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 reco mmended by E.I.Tec to ensure parts most likely to require replac ement 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 oper ation is warranted. 6. Once the incident has been repaired, follow start-up procedures. Temporarily increase lime flow, if warranted, to re-establis h lime build-up on bags. 7. Complete all required paperwork

Steps Taken to Minimize Emissions:

1. Stopping bag cleaning while determini ng cause will ensure the build-up on the bags is not further reduced. 2. Continuing to flow the exhaust through one or more c hambers of the control (if possible) will provide some amount of emission reduction. INCIDENT 2-14 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 pres ent. 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 ti me-based cleaning as backup to pressuredrop based cleaning) 3. Check for lime in the hopper 4. Determine if exhaust can still safely v ent through one or more chambers of baghouse. If so, continue to vent thr ough 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-est ablished, restart cleaning process.

7. Increase lime feed to reestab lish lime in system, if necessary. 8. Complete all required paperwork

Steps Taken to Minimize Emissions:

1. Since there will continue to be lime bu ild-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 maximu m amount of cleaning possible. INCIDENT 315 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 thr ough 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 rem edy 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 syst em to automatically discontinue limefeed (to prevent lime blockages caus ed 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 416 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 pr oblem, 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, fo llow 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 repai red, 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 woul d most often be the case) as soon as practicable. Then, those bag(s) woul d be closed or blinded and the exhaust will be vented through the remaining modules. INCIDENT 517 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 o F

Steps Taken to Correct Problem:

1. If warning alarm, take appropriate action to safely reduce temperature. 2. Determine if short term bypass is nece ssary 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 o F, 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 repai red, 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 po ssible to safely vent through system. INCIDENT 618 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 v ent through one or both chambers of the baghouse. If so, continue to vent thr ough baghouse. If not, switch to bypass

mode. 4. Depending on root cause, follow rem edy 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 repai red, follow start-up procedures. 7. Complete all required paperwork

Steps Taken to Minimize Emissions:

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

raw gas. INCIDENT 719 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 thr ough 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 repai red, 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 820 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 v ent through one or both chambers of the baghouse. If so, continue to vent th rough baghouse. If not, switch to bypass mode. If kiln and DIFF shutdown is imminent, switch to bypass to avoid lengthy

shutdown and star tup procedure. 3. Depending on root cause, follow rem edy 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 repai red, follow start-up procedures. 6. Complete all required paperwork

Steps Taken to Minimize Emissions:

1. Boral will identify the r oot cause of the problem. If cause is determined to be compressor related, Boral will provi de portable compressor to replace or supplement air supply. INCIDENT 921 Type of Malfunction: 

### Mechanical Equipment Failure

Possible Causes : Equipment Malfunction Type of Alarm: Warning Ala rm 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 v ent through one or both chambers of the baghouse. If so, continue to vent thr ough 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 wh ich equipment is o ff-line or otherwise impaired. 4. Notify appropriate maintenance or other responsible personnel. 5. Respond to correct or repair the ma lfunction in a safe, efficient and timely manner as soon as it is practicable. 6. Follow procedures i ndicated 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 1022 Type of Malfunction: 

### Loss of Power or Gas

General Steps Taken to Correct Malfunction and Reduce Emissions

 Ensure that the situation has becom e stable and the hazards have been cleared before proceeding further.

 Confirm the system status and note whic h equipment is o ff-line or otherwise impaired.

 Notify appropriate maintenance or other responsible personnel.

 Respond to correct or repair the malf unction in a safe, efficient and timely manner as soon as it is pr acticable, 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 practic able until compliance can be assured if failure cannot be repaired in a timely manner. INCIDENT 1123 Type of Malfunction: 

### Acts of God

General Steps Taken to Correct Malfunction and Reduce Emissions

 Ensure that the situation has becom e stable and the hazards have been cleared before proceeding further.

 Confirm the system status and note whic h equipment is o ff-line or otherwise impaired.

 Notify appropriate maintenance or other responsible personnel (see Sections 5 - 8).

 Respond to correct or repair the malf unction in a safe, efficient and timely manner as soon as it is pr acticable, for example:

o Right overturned equipment and atte mpt to reinstall/restart; and

o Ensure all power and gas lines are func tioning correctly and are free from

defect

 Suspend operations as soon as practic able until compliance can be assured if failure cannot be repaired in a timely manner. INCIDENT 1224 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 t he 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 shoul d be reviewed and signed by the Shift Supervisor and any additi onal comments added.

ACTIONS

 Operator should notify the Shift S upervisor about the incident as soon as practicable.

 If the problem cannot be co rrected 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 dut y should collect the information needed to complete the Incident Repor t Form prior to the end of t he shift or no later than 24 hours following the malfunction and subm it 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 Environm ental Supervisor. Retain the original

form in the shift f iles for five (5) ye ars [§63.10(b)(1)].

 Enter Incident into Incident/Malfunction Log (optional)25 5.0 REPORTING REQUIREMENTS

What Will Be Reported to Regulatory Au thority When There is a Malfunction

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

will state this fact in our semiannual ex cess 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 t he owner/operator or other responsible official;

o Statement that the actions taken dur ing 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 info rmation (see Appendix B for an example form);

o Whether any excess emissions and/or parameter moni toring 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 we re 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 incl uded in the current Malfunction Plan, and excess emissions occurred, the Envir onmental 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 s hould include the following information (§63.10(d)(5)(ii)):

o Name, title, and certifying signat ure of responsible official;

o Detailed explanation of the circ umstances 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 malf unction were not consistent with the

Malfunction Plan or did not address t he particular type of malfunction that occurred, and the Boral Malfunction Plan should include these events or actions for future events, then the Environm ental 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 maintain ing the source during similar malfunction events, with a program of corrective action to address the malfunctions; and

o Report the revisions of your Malf unction 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 t he 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 thes e 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 FORMSBORAL BRICK Bessemer, AL

INCIDENT REPORT

MALFUNCTIONING DEVICE:

_______________ _________

DATE OF INCIDENT:

____________ __________________

Explanation of Incident (include su spected cause- can reference Incident Code, if appropriate)

Determination that incident w as 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- emissi ons 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 Minimi ze Emissions During Problem

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

Signature: ______

_____________ Date: _________________________ If the answer to questions 1 and/or 2 a bove is NO, answer questions 3 through 5,

unless incident is determined to NO T 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 St art-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 BrickBessemer, ALIncident/Malfunction TrackingDateTrackingNumberWas theIncident aMalfunction?If YES, wasthe SMMPfollowed?If SSMP not followed....Who completedthis log?SeeNote1Was 2nddayreport calledin or faxed?Was 7thdayreport mailedWas SSMPmodified?1Add a reference letter to this column, ifyou need to add additional information below:abcd-BORAL Brick Bessemer, AL



# APPENDIX C

LOG OF CHANGES TO SSMPBORAL Brick Bessemer, AL



# Change Log for SSMP Revisions

DATE Changes (non-editorial) Initials