1

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 BRICK 

Muskogee Facility 

DATE OF ORIGINAL PLAN: 

May 14, 007 

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 

********************************************************************** 

Prepared by: 

Susan J. Miller 

Innovar Environmental 

Cary, NC 
2

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 

(Bundy Environmental), it is not intended to replace 

this document. 

Supplemental information, such as detailed system 

parameters, can be found in that document. 

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3

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 facilitydeveloped 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 Overview 

Boral’s Muskogee facility has one brick production facility with one kiln with a 

production capacity of over 10 tons per hour. Therefore, the kiln is subject to 

the control requirements of the Brick MACT. The kiln is controlled with a Bundy 

dry injection fabric filter (DIFF) system. A dry reagent (hydrated lime) is 

injected to scrub the acid gases from the kiln gas. This lime is injected into the 

duct after the dilution air gas cooler through a patented injection device. This 

injection section accelerates the gas and disperses the reagent across the 

entire gas stream for maximum contact and scrubbing. As soon as the reagent 

is injected, it begins to react with the pollutants to form solid products that will 

be removed in the fabric filter. 

The baghouse is comprised of four factory assembled modules. A manifold 

system connects the modules and provides for single point ductwork 

connections at the inlet and outlet. The manifolds are designed so that there is 

reasonably even gas and particulate distribution to all of the modules, and are 

also designed so that dust and reagent do not fall out in the inlet manifold. The 

system is oversized so that a module can be isolated for maintenance while the 

remainder of the system continues to operate. 
4

Boral is committed to running the kiln, control, and all monitors to ensure 

ongoing emission reduction, while protecting both the integrity of the system 

(which ensures ongoing emission reduction) and safety. 
5

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 

Muskogee 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. 

 Revised 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 

As with all controls, there will likely be periods when the DIFF at 

Boral Muskogee does not operate exactly at the optimal 

conditions. It is important to note that our operators use a 

different definition of the term “malfunction” than the regulatory 

definition in the Brick MACT, with Boral using the term much 

more broadly. To be clear, Boral will use different terms. Boral 

will be tracking each “incident” where a piece of equipment fails 

to operate as expected. As part of the tracking and review 

process, we will determine whether or not this event constitutes 

a malfunction under the MACT. 

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

“incident” to refer to incidents when the control actually is (or 

appears to be) operating out of normal range. We will use the 

term “MACT malfunction” to define an incident/malfunction that 

is considered a malfunction under §63.6(e)(3). 

********************************************************************* 

To ensure that this plan is followed, each incident will be recorded on an 

Incident Report. If the incident is determined to be a MACT malfunction, the 

information will be entered into the MACT Malfunction tracking spreadsheet. If 

the procedures during the MACT malfunction match the procedures in this 

manual, the tracking is minimal. If alternative procedures are followed- or if the 

malfunction is not in the current SSMP, additional actions are required. These 

procedures are outlined in Sections 4 and 5 of this document. 
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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. Venting at too high a temperature could damage the 

bags which would lead to visible and gaseous emissions. [It should be 

noted that Boral uses bags appropriate for the expected temperature 

ranges to be encountered. 

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

vented through the control. Exhausting when there is no clear path (e.g., 

dampers closed to all cleaning modules) would damage the control, 

creating potential safety issues and potentially damaging the integrity of 

the cleaning process. 

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

lime could damage the system. For example, the lime flow would be 

halted if there is not sufficient flow since the lime needs sufficient air flow 

to keep the particles suspended and to avoid blockages. 

All of these principles were considered when the procedures were developed. 
8

3.1 STARTUP PROCEDURES 

This section describes the start-up procedures for the kiln and the Bundy DIFF. 

The Bundy DIFF was brought on-line while the kiln is in operation. The 

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

following page. [NOTE: the main procedure listed below is identical to the 

procedure listed on page 9 of Section III of the Bundy manual. The 

descriptions in the small text boxes provide additional information, including 

discussion of how the procedures minimize emissions]. 

This same general procedure is followed for each start-up of the control/kiln. 

However, some steps are skipped if previously completed. 

In general, there are three possible start-up scenarios that could occur: 

 Cold kiln, cold control. This procedure is followed after an extended 

kiln downtime. The procedure on the following page is based on a cold 

kiln, cold control start. 

 Hot kiln, cold control. This procedure would be followed if the kiln was 

operated in bypass mode for an extended period of time. 

 Hot kiln, hot control. This would be a re-start after some event caused 

the control to switch to bypass for a short period of time. Other than 

bypasses that occur for routine maintenance, an example of these 

events would be a brief power outage that causes the system dampers 

to close. In this event, the restart procedure would still run through the 

system checks, but most steps would shortened since both the 

baghouse and the exhaust would be up to the correct temperature. 

An important thing to note is that the kiln can be exhausted to the control device 

once the exhaust is up to temperature. This required temperature (300 oF) is 

well below the temperature required for the hazardous air pollutants of concern 

(HF and HCl) to be liberated from the brick (i.e., a minimum of 700 oF). 
9

START-UP PROCEDURES- At the end of the following procedure, the kiln 

exhaust stream will automatically switch from bypass to passing through the 

control. While these could be done manually, Boral procedure is that these are 

all done automatically once all alarms have been acknowledged. 

a. Prior to starting the scrubber system, the kiln should be 

brought up to temperature through the bypass to avoid 

damage to the bags. 

b. The system start-up is automatic from the main control 

panel. However, the operator has the ability to control 

each piece of equipment manually as well. 

c. Prior to starting the system, the baghouse hopper heaters 

should be enabled. This will assist in pre-heating the 

baghouse. Each module's hopper heater is enabled 

individually from the touch screen. The heaters will then 

turn on and off automatically in response to a signal from 

the local thermostat. 

d. At the initiation of the start-up process, the following 

conditions should exist: 

i. Compressed air available and turned on 

ii. Hopper heaters enabled 

iii. Bypass in "AUTO" 

iv. Dilution air system in "AUTO" 

v. All baghouse modules "ACTIVE" 

vi. Reagent blower in "AUTO" 

vii. Lime Feeder in "AUTO" 

viii. Spent Lime Removal System in “AUTO” 

ix. All hopper rotary airlock local switches in "AUTO". 

Each active module’s rotary airlocks will cycle on 

and off whenever the following conditions are met: 

(a) Local switch in "AUTO" 

(b) Module is "ACTIVE" 

(c) Spent Lime Blower is running 

(d) That module’s conveying line is proven open 

x. Baghouse cleaning in "AUTO" 

e. Once kiln operation is stable the I.D. fan can be started 

f. Once the fan is started, the rest of the start-up process will 

automatically continue. 

i. The baghouse module isolation valves will open 

ii. Once the module isolation valves for at least two 

modules are proven open, the bypass will close. 

iii. Once the bypass is proven closed, the reagent 

blower will start. 

iv. After the reagent blower has been operating for at 

least 15 minutes the lime feeder will start. 

v. The dilution air system will start automatically when 

required to control the baghouse inlet temperature.
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Steps to Minimize Emissions During Start-Up Procedures: 

 The system will not start until all error codes have been corrected. This 

ensures that the control can operate only when systems are operating 

properly, which ensures emissions are minimized. 

 The temperature of the system must be brought up to temperature 

before the control is switched from bypass. If the exhaust is not up to 

acceptable temperatures, the control can be damaged, thereby 

increasing the time that controls are not operational. 

 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. If the control and/or the 

kiln need to be stopped, the following general principles impact the procedures 

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

continue to vent through the control device until the exhaust reaches the 

low temperature set point (275 oF). 

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

control is threatened, all procedures will be aimed at minimizing 

avoidable emissions of HAP to the atmosphere. 

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

be documented as being part of the time allowed under the Routine 

Maintenance Bypass Allowance. 

The standard shutdown procedures for the kiln and control device are 

described on the following page. [NOTE: the main procedure listed below is 

identical to the procedure listed on page 13 of section III of the Bundy manual.] 

a. General - The system shut down will be manual from the 

main control panel. The operators will stop or disable each 

piece of equipment individually. 

b. Short Term Shut Down – Following is the procedure for 

shutting the system down for a short period of time 

(typically less than 8 hours) 

i. Turn off the lime blower and feeder. Allow the 

blower to run for at least 5 minutes after the feeder 

has been shut off to purge the conveying line. 

ii. Open the bypass valve. 
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iii. Once the bypass valve is fully open, turn off the I.D. 

fan. The baghouse module inlet and outlet valves 

will close automatically. 

iv. Leave the hopper heat and material removal system 

operating. If maintenance on a module is required, 

disable the hopper heat and rotary airlock for that 

module. 

c. Long Term Shut Down – Following is the procedure for 

shutting the system down for a long period of time or if 

entrance inside the system is required. 

i. Follow the procedure for short term shut down. 

ii. Turn the baghouse cleaning to “CONTINUOUS”. 

Allow the cleaning to run through 2-3 cycles to get 

most of the particulate off the bags. 

iii. The spent lime conveying system, rotary airlocks 

and hopper heaters may be turned off after all 

material is removed from the hoppers. 

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 INDICATION 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. 

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 
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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 one or more of the baghouse 

modules, even if lime flow has stopped), 

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

emissions, or both, to the extent practicable during any MACT malfunction. 

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 Bundy manual. 

The Bundy DIFF has three categories of alarms: 

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

personnel safety or equipment integrity in danger. 

2. System Alarm – An alarm that is triggered by an event that affects 

other components in the system but does not indicate current 

personnel equipment danger. 

3. Indication Alarms – 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. 

A critical 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 system or indication alarm that would indicate 

problems before they would rise to the level of a critical alarm. 

Boral responds to both system and indication 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. 

Incident # Condition Type of Alarm 

1 Pressure drop across baghouses too high Indicator 

2 Pressure drop across baghouses too low None 

3 Limeflow too low and/or stopped Indicator 

4 Airflow too low System 
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5 Visible emissions from stack None- visible inspection 

6 High temperature in baghouse System alarm at 425 oF 

Critical alarm if > 475 oF 

7 Reduced compressed air pressure Critical alarm 

8 Low temperature in baghouse System alarm at 300 oF 

System alarm at 275 oF 

9 Mechanical/Equipment Failure 

10 Loss of power or natural gas 

11 Acts of God 

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NOTE: 

At the end of this section, Boral has reproduced the troubleshooting table from 

the Bundy manual for ease of use. It is important to note that NOT ALL 

CONDITIONS LISTED IN THE BUNDY TABLE ARE MACT MALFUNCTIONS. 

The conditions that Boral has determined are most likely to create MACT 

Malfunction conditions are listed in the above table. 

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Type of Malfunction: Pressure Drop Higher Than Acceptable 

Range 

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

timing or insufficient compressed air); faulty 

pressure indicator, re-entrainment of lime low 

fan motor amperage 

Type of Alarm: Indicator alarm 

Steps Taken to Correct Problem: 

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

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

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

bypass mode. 

3. Depending on root cause, follow remedy steps listed in the Bundy 

Troubleshooting Table reproduced at the end of this section. 

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

evaluate whether change in kiln operation is 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 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 Bundy to ensure parts 

most likely to require replacement are available. 

INCIDENT 1
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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; bag 

failures 

Type of Alarm: None-Determined from Kiln Pressures and 

Baghouse

Steps Taken to Correct Problem: 

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

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

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

bypass mode. 

3. Depending on root cause, follow remedy steps listed in the Bundy 

Troubleshooting Manual reproduced at the end of this section. 

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, if the 

system was shut down. If warranted, increase lime flow for a short 

periodas airflow allows. 

6. Complete all required paperwork 

Steps Taken to Minimize Emissions: 

1. Increasing the lime feed helps build the lime cake up on the bags faster. 

The increase builds it up as soon as possible without causing other 

problems. 

2. If the exhaust is down there are no emissions. 

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; eductor failure/requiring replacement 

Type of Alarm: Audible and Visual Alarm

Steps Taken to Correct Problem: 

1. Check for lime in the hopper 

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

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

bypass mode. 

3. Discontinue bag cleaning until flow has been re-established (should be 

automatic since bag cleaning based on pressure drop). 

4. Remove blockage, if present. 

5. If lime flow must be stopped for repair/replacement, follow procedures in 

Bundy manual. 

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

evaluate whether change in kiln operation is warranted. 

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

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 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. Discontinuing bag cleaning during this incident will ensure that lime 

remains on the bags to provide the maximum amount of cleaning 

possible. 

INCIDENT 3
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Type of Malfunction: Airflow Through System Too Low 

Possible Causes: Exhaust Fan Failure

Type of Alarm: There is an audible alarm if the I.D. fan 

VFD faults. The system will automatically 

bypass on a fan VFD fault or loss of run 

signal. 

Steps Taken to Correct Problem: 

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

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

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

bypass mode. 

3. Depending on root cause, follow remedy steps listed in Bundy Manual 

(see table at the end of this section). 

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. 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
18

Type of Malfunction: Visible Emissions from Stack 

Possible Causes: Bag breakage; improper seal at tube sheet; 

insufficient filter cake 

Type of Alarm: None- determined from visible observation 

Steps Taken to Correct Problem: 

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

2. To check for bag breakage, systematically close off one module at a 

time until location of leak can be determined. 

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

remaining, non-leaking modules. 

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

safely vent through one or more baghouse modules while work 

continues to fix the malfunctioning equipment. If so, continue to vent 

through baghouse. If not, switch to bypass mode. 

5. Depending on root cause, follow remedy steps listed in Bundy Manual 

(see table at the end of this section and/or Failed Bag Location and 

Replacement in IV.C.4 of Bundy manual). 

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

evaluate whether change in kiln operation is warranted. 

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

8. Complete all required paperwork 

Steps Taken to Minimize Emissions: 

1. Boral will seek to identify whether a single baghouse module is causing 

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

practicable. Then, the exhaust will be vented through the remaining 

modules. 

INCIDENT 5
19

Type of Malfunction: High Temperature in Baghouse

Possible Causes: Dilution air fan failure 

High kiln exhaust temperature 

High kiln exhaust flow

Type of Alarm: System alarm at 425 oF (“High temperature”) 

Critical alarm if > 475 oF (“High-high 

temperature”) 

Steps Taken to Correct Problem: 

 If critical alarm, DIFF will automatically switch to bypass to avoid 

damage to the DIFF. 

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

 If temperature remains below 475 oF, continue to vent through 

one or more baghouse modules, unless there is a personnel safety or an 

additional control device integrity issue. 

 Depending on root cause, follow remedy steps listed in Bundy 

Manual (see table at the end of this section). 

 If malfunction cannot be repaired in 4 hours, notify management 

to evaluate whether change in kiln operation is warranted. 

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

 Complete all required paperwork 

Steps Taken to Minimize Emissions: 

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

ensure that the Critical Alarm is not triggered. 

INCIDENT 6
20

Type of Malfunction: Reduced Compressed Air Pressure 

Possible Causes: Compressed air consumption too high; 

restriction in piping; dryer plugged; 

compressor not operating properly 

Type of Alarm: Indicator alarm if pressure drops below 70 

psi 

Critical alarm if pressure drops below 60 

psi

Steps Taken to Correct Problem: 

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

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

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

bypass mode. 

3. Depending on root cause, follow remedy steps listed in Bundy Manual 

(see table at the end of this section). 

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. In all past cases 

this has been an electrical problem specific to 1 module. We then 

disable that module and correct the problem. 

INCIDENT 7
21

Type of Malfunction: Low Temperature in Baghouse 

Possible Causes: Dilution air control failure, low process 

exhaust rate or temperature

Type of Alarm: System alarm if temperature drops below 

300 oF 

Critical alarm if temperature drops below 

275 oF

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 more 

baghouse modules. If so, continue to vent through baghouse. If 

not, switch to bypass mode. 

4. Depending on root cause, follow remedy steps listed in Bundy 

Manual (see table at the end of this section). 

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. Switch to bypass at critical alarm protects the integrity of the control and 

ensures that the control can be switched back on as soon as the issue is 

resolved. 

INCIDENT 8
22

Type of Malfunction: Mechanical Equipment Failure 

Possible Causes: Equipment Malfunction 

 

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 more 

chambers of the baghouse. If so, continue to vent through 

baghouse. If not, switch to bypass mode. 

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 Bundy manual (table reproduced at 

the end of this section). 

Steps Taken to Minimize Emissions: 

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

quick repair of malfunctioning device. 

INCIDENT 9
23

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 company 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 10
24

Type of Malfunction: Acts of God 

 

 

General Steps Taken to Correct Malfunction and Reduce Emissions

 Ensure that the situation has become stable and the hazards have been 

cleared before proceeding further. 

 Confirm the system status and note which equipment is off-line or 

otherwise impaired. 

 Notify appropriate maintenance or other responsible personnel (see 

Section 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 11 
25

SYMPTOM CAUSE REMEDY 

High Baghouse 

Pressure Drop 

Incorrect Pressure Reading Clean Pressure Taps 

Check hoses for leaks 

Check diaphragm in gauge 

 Bag cleaning not adjusted properly Increase cleaning frequency 

Increase compressed air 

pressure 

 Insufficient compressed air pressure Increase pressure 

Check dryer and clean if 

necessary 

Check piping for closed 

valves or other obstructions 

 Pulse valves failed Check diaphragms 

Check solenoids 

Check PLC/pulse panels 

 Cleaning timer failure Check to see if timer is 

indexing all contacts 

Check output on all 

terminals 

NOTE: 

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

ease of use. It is important to note that NOT ALL CONDITIONS LISTED IN THE 

BUNDY TABLE ARE MACT MALFUNCTIONS. The conditions that Boral has 

determined are most likely to create MACT Malfunction conditions are listed in the 

table at the beginning of this section. 
26

SYMPTOM CAUSE REMEDY 

High Baghouse 

Pressure Drop 

Dust not being removed from bags Increase air pressure 

Condensation on bags (see 

below) 

Send bag to lab for analysis 

Replace bags 

 Excessive re-entrainment of dust Check hopper for plugging 

Continuously empty hopper 

Clean rows of bags randomly 

instead of sequentially 

 Baghouse undersized Consult supplier 

Low Fan Motor 

Amperage/Low 

Gas Volume 

High baghouse pressure drop 

Fan and motor sheaves reversed 

See above 

Check drawings and reverse sheaves 

 Duct plugged with dust Clean out duct and check duct 

velocities 

 Damper(s) closed Check all duct dampers 

 System static pressure too high Measure static on both sides of fan 

and review with design 

Duct velocity too high 

Duct design not proper 

 Fan not operating per design Check fan inlet 

configuration and be sure 

even air flow exists 

Check impeller for wear 

 Fan belts slipping Check tension and adjust 

Replace belts 

 Fan rotation incorrect Check rotation with 

indicator on fan or drawings 
27

SYMPTOM CAUSE REMEDY 

Dust Escaping at 

Source (Puffing) 

Low Air Volume See above 

 Ducts leaking Patch duct leaks so air does 

not by-pass source 

 Improper duct balancing Adjust dampers in duct branches 

Dirty discharge Bags leaking Replace bags 

Plug or cap broken bags and replace 

later 

 Improper seal at tubesheet Check bag/cage/tubesheet 

attachment 

 Failure in seals of joints at 

clean/dirty air connection 

Caulk or weld seams 

 Insufficient filter cake Allow more particulate to 

build on bags by cleaning 

less frequently 

 Bags too porous Send bag for permeability 

testing and review with 

supplier 

Excessive Fan 

Wear 

Fan handling too much particulate See above 

 Improper fan design Check application with 

manufacturer 

 Fan speed too high Check with manufacturer 
28

SYMPTOM CAUSE REMEDY 

Excessive Fan 

Vibration 

Build-up of dust on blades Clean off and check to see if fan is 

handling too much particulate (see 

above) 

Check for moisture in fan 

 Incorrect fan wheel for application Check with manufacturer 

 Sheaves not balanced Have sheaves dynamically balanced 

 Bearings worn Replace bearings 

High Compressed 

Air Consumption 

Cleaning cycle too frequent Reduce cleaning cycle 

frequency if possible 

 Pulse duration too long Reduce duration (after initial shock 

all other compressed air is wasted) 

 Pressure too high Reduce supply pressure if possible 

 Diaphragm valve failure Check diaphragms and springs 

Check solenoids 

Reduced 

Compressed Air 

Pressure 

Compressed air consumption too 

high 

See Above 

 Restrictions in piping Check piping 

 Dryer plugged Replace desiccant 

 Supply pipe too small Review design 

 Compressor not operating properly Consult manufacturer or compressor 

maintenance manual 
29

SYMPTOM CAUSE REMEDY 

Premature Bag 

Failure – 

Decomposition 

Bag material improper for chemical 

composition of gas or particulate 

Analyze gas and particulate 

and consult with supplier 

Treat with neutralizer before 

baghouse. 

 Operating below acid dew point Increase gas temperature 

By-pass at start-up 

High Bag Failure – 

Wearing Out 

Ladder vane baffles worn out Replace ladder vane baffles 

 Particulate loading too high Install mechanical collector ahead 

of baghouse 

 Cleaning cycle too frequent Reduce cleaning frequency if 

possible 

 Improper bag support on cages Consult supplier 

High Bag Failure – 

Burning 

Sparks entering baghouse Install spark arrestor 

 Stratification of hot and cold gasses Force turbulence in duct with 

baffles 

 Thermocouple failed Replace and determine cause of 

failure 

 Failure of cooling device Consult Manufacturer 
30

SYMPTOM CAUSE REMEDY 

Moisture in 

Baghouse 

Insufficient pre-heating Check hopper heater operation 

Run system with hot air only before 

starting process gas flow 

 System not purged at shut down Run fan for 15-20 minutes after 

process is shut down 

 Wall temperature below dew point Raise gas temperature 

Insulate baghouse 

Check hopper heaters 

 Cold spots through insulation Eliminate direct metal line through 

insulation 

 Pulse air introducing water Check air line drains 

Install air dryer 

Damper Valve 

Inoperative 

(Sticking) 

Over travel of air cylinder Adjust length of travel 

Replace cylinder if required 

 Improper lubrication Fill compressed air oiler 

Replace oiler 

 Water in air line Add dryer to air line 

Check air line drains 

Replace desiccant in dryer 

Replace moisture trap 

Damper Valve 

Fails To Operate 

Low air pressure See above 

 Solenoid failure Check power to solenoids 

Replace solenoids 

 Damper locked out Verify reason for lock out and 

remove lock when safe 
31

SYMPTOM CAUSE REMEDY 

Material Bridging 

in Hopper 

Moisture in baghouse See above 

 Material being stored in hopper Empty hopper continuously 

 Improper vibration Change the vibration amplitude an 

frequency 

 Ash conveyor plugged Clean ash conveyor 

 

High Baghouse 

Inlet Temperature 

Dilution air system failure Verify dilution air fan operation 

Verify dilution damper operation 

 

Low Baghouse 

Inlet Temperature 

Dilution air control failure Check dilution air fan speed 

Check dilution air damper position 

 Low process exhaust rate or 

temperature 

Increase process temperature or rate 

if possible 

 

Loss of Lime Feed Lime silo empty Verify lime silo level 

 Lime bridging or rat-holing in silo Increase frequency or amplitude of 

bin discharger vibration 

 Lime bridging or rat-holing in 

feeder 

Verify feeder agitator paddle 

operation 

 Lime build-up in eductor Change and clean eductor 

 Lime build-up in conveying line Inspect and clean conveying line 

 Lime build-up in injection pipe Change and clean injection pipe 

 
32

4.0 RECORDKEEPING REQUIREMENTS 

We will track all start-up and shutdown events. {Need to define what you will use as the 

beginning and ending point of both “start-up” and “shutdown”; You could explain here if 

you define “operating hours” differently from the time between the end of start-up and 

the beginning of shutdown- since bypass is based on “operating hours.”} 

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. 

 The operator on duty should 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 Shift Supervisor should review 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) 
33

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 A 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 (reports are due on January 31 and July 31 

of each year). 
34

 

APPENDIX AEXAMPLE REPORT FORMS 
BORAL BRICK

Muskogee, OK 

INCIDENT REPORT FORM 

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, sign below and stop. List 

malfunction in semi-annual report. 

TRACKING 

NUMBER: ________ 
BORAL BRICK

Muskogee, OK 

INCIDENT REPORT FORM 

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

Immediate reporting required. SEE SECTION 5 OF BORAL’s 

SSMP MANUAL 

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

Muskogee, OK 

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

Muskogee, OK 

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- 
APPENDIX B-

 LOG OF CHANGES TO SSMP 
Change Log for SSMP Revisions 

DATE Changes (non-editorial) Initials