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

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Prepared by:

Susan J. Miller

Innovar Environmental Cary, NC2 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.

********************************** ************************** *************************3 1.0 INTRODUCTION

The Brick MACT (40 CFR Part 63, s ubpart JJJJJ) requires that an affected source be operated in compliance with the em ission limitations at all times. For periods of startup, shutdown, and malf unction, the emission limitations do not apply; however, during these times, the facility must comply with a facilitydeveloped start-up, shutdow n, and malfunction plan (SSMP). This SSMP is applicable to the kiln, the air polluti on control device, and the monitoring equipment.

Boral Brick (Boral) is committed to ens uring compliance with the Brick MACT and the requirements in the General Prov isions of Part 63 (Subpart A), which apply to all sources subject to an indus try-specific MACT (e.g., the Brick MACT). As required by the Brick MA CT, Boral will operate and maintain any affected source and any air polluti on control equipment and monitoring equipment that is used to meet the standar d in a manner consistent with safety and good air pollution control practices fo r 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 pr acticable after their occurrence in
accordance with this SSMP. To the ex tent that an unexpected event arises during a startup, shutdown, or malfuncti on, Boral will comply by minimizing emissions during such a startup, shut down, and malfunction event consistent with safety and good air pollution control practices.

1.1 Facility Overview

Boral’s Muskogee facility has one brick pr oduction 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) syst em. 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 th rough 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 fact ory assembled modules. A manifold system connects the modules and pr ovides for single point ductwork

connections at the inlet and out let. The manifolds are designed so that there is reasonably even gas and particulate distri bution 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 c an be isolated for maintenance while the remainder of the system c ontinues to operate.4 Boral is committed to running the kiln, control, and all monitors to ensure ongoing emission reduction, while protec ting both the integr ity of the system (which ensures ongoing emission reduction) and safety.5 2.0 PURPOSE

The purpose of this document is to co mply with the MACT requirements related to developing and complying with a SSMP. The purpose of an SSMP [§63.6(e)(3)] is to ens ure that a facility:

 Is operated and maintained in a m anner that meets the general duty

clause to minimize emissions

 Corrects malfunctions as soon as prac ticable 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 cit ed below are addressed in our plan

 Section 63.6(e)(3) of Subpart A, G eneral Provisions and §63.8420(c) of Subpart JJJJJ requires that we deve lop and implement a Startup, Shutdown, and Malfunction Plan for oper ations used to comply with the Brick and Structural Clay Products MACT.

 Section 63.6(e)(3) of Subpart A, G eneral Provisions, requires Boral Muskogee to describe what corrective ac tion we will take if a malfunction occurs at an affected process, air pollution control or monitoring equipment.

 In addition to the requirements to dev elop 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.6 ********************************************************************* Defining MACT Malfunctions

As with all controls, there will li kely 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, wit h Boral using the term much more broadly. To be clear, Boral wil l use different terms. Boral will be tracking each “incident” wh ere 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 doc ument, we will use the term

“incident” to refer to incidents wh en the control actually is (or appears to be) operating out of normal range. We will use the
term “MACT malfunction” to defi ne 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 inci dent is determined to be a MACT malfunction, the information will be entered into the MACT Malfunction tracking spreadsheet. If the procedures during the MACT malfunc tion match the procedures in this manual, the tracking is minimal. If alter native procedures are followed- or if the
malfunction is not in the current SSMP , additional actions are required. These procedures are outlined in Sectio ns 4 and 5 of this document.7 3.0 START-UP, SHUTDOWN, AND MALFUNCTION PROCEDURES

In general, the focus of our procedures is to protect both t he integrity of the control system and reduce the emissions to the atmosphere. Boral believes

that both are critical to ensuring the long-term emissi on reduction ability of the system. In addition, the safe ty of plant personnel and visitors is always the first priority.

To balance these, Boral follows the following general principles:

 The exhaust from the k iln is vented through the control device when the stack temperature is wit hin the acceptable range. Venting at too low a temperature could cause moisture to enter the syst em and cause the lime to solidify. Venting at t oo high a temperature could damage the bags which would lead to visible and gaseous emissions. [It should be noted that Boral uses bags appropri ate for the expected temperature ranges to be encountered.

 There must be a clear path though t he system for the exhaust to be vented through the control. Exhausting when there is no clear path (e.g., dampers closed to all cleaning modul es) 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 ex ample, 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 proc edures 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 proc edure 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 pr ovide additional information, including discussion of how the procedur es minimize emissions].

This same general procedure is followed fo r each start-up of the control/kiln. However, some steps are skipped if previously completed.

In general, there are three possible st art-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 restar t procedure would still run through the system checks, but most steps wo uld 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 temperatur e. This requir ed temperature (300 o F) 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 o F).9 START-UP PROCEDURES- At the end of the followi ng procedure, the kiln exhaust stream will automatically swit ch from bypass to passing through the

control. While these could be done manual ly, 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 autom atic 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 sy stem, the baghous e hopper heaters

should be enabled. This will a ssist 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 star t-up process will automatically continue. i. The baghouse module isol ation 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 lim e feeder will start.

v. The dilution air system will start automatically when required to control the baghouse inlet temperature.10 Steps to Minimize Emissions During Start-Up Procedures :

 The system will not start until all erro r codes have been corrected. This ensures that the control can oper ate 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 swit ched from bypass. If the exhaust is not up to acceptable temperatures, the control can be damaged, thereby increasing the time that c ontrols 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 o F).

 Unless safety to Boral personnel and vi sitors or ongoing integrity of the control is threatened, all procedur es 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 fo r 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 oper ators 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 blow er 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.11 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 ro tary 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 appr oach 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 sa fety 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 requirem ents are also met.

Boral’s approach to minimizing emissi ons during a malfunction incident is to review the potential to minimize the tw o primary factors that influence overall

emissions: duration and concent ration 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 re sponse) are onsite at all times

the kiln and contro l 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 each12 incident) determine if it is possible to continue to vent through the control device, or part of the c ontrol device while the inci dent/MACT malfunction is being addressed (e.g., venting th rough one or more of the baghouse modules, even if lime flow has stopped),

Boral will either minimize the lengt h of the downtime or the amount of emissions, or both, to the extent pr acticable during any MACT malfunction.

The following sections include lists of s pecific procedures to be followed when an incident occurs that could potent ially be considered a MACT malfunction
under the Brick MACT. This list is bas ed on a list of conditions that could have a direct impact on emissions, either immediat ely 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 dev ice 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 equi pment 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 c ause 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 comp romised. Protecting the integrity of the system will ensure a more rapid return to normal opera tion 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 indicati on 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 i dentified 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 System13 5 Visible emissions from stack None- visible inspection 6 High temperature in baghouse System alarm at 425 o F
Critical alarm if > 475 o F 7 Reduced compressed air pressure Critical alarm 8 Low temperature in baghouse System alarm at 300 o F System alarm at 275 o F 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 troubles hooting 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 determi ned are most likely to create MACT

Malfunction conditions are listed in the above table.

********************************** ******************************* *************************14 Type of Malfunction: 

### Pressure Drop Higher Than Acceptable Range

Possible Causes : Inefficient cleaning cycle in baghouse (e.g., timing or insufficient co mpressed 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 t he end of this section. 4. If malfunction cannot be repaired in 4 hours , notify management to evaluate whether change in ki ln operation is 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 lik ely 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 115 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 ki ln 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 216 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 fl ow 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 repai r/replacement, follow procedures in Bundy manual. 6. If malfunction cannot be repaired in 4 hours , notify management to evaluate whether change in ki ln operation is warranted.
7. Once the flow has been re-est ablished, 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 th is incident will ensure that lime remains on the bags to provide the maximum amount of cleaning possible. INCIDENT 317 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 re medy 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 ki ln 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. Exhaust will continue to flow th rough the system unless it will cause a danger to personnel or the equipmen t. This will ensure that the maximum possible emission reducti on is still achieved during the

incident.

. INCIDENT 418 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, systemat ically close off one module at a

time until location of leak can be determined. 3. If bag breakage in one module is t he cause, continue to vent through remaining, non-leaking modules. 4. If the issue is other than bag br eakage, determine if exhaust can still safely vent through one or more baghouse modules while work continues to fix the malfunctioning equi pment. If so, c ontinue to vent through baghouse. If not, switch to bypass mode. 5. Depending on root cause, follow re medy steps listed in Bundy Manual (see table at the end of this sect ion 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 ki ln operation is warranted. 7. Once the incident has been repai red, follow start-up procedures. 8. Complete all required paperwork

Steps Taken to Minimize Emissions:

1. Boral will seek to identify whet her a single baghouse module is causing the visible emissions (this would mo st often be the case) as soon as practicable. Then, the exhaust will be vented through the remaining

modules. INCIDENT 519 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 o F (“High temperature”)
Critical alarm if > 475 o F (“High-high temperature”)

Steps Taken to Correct Problem:

If critical alarm, DIFF will automatically swit ch to bypass to avoid damage to the DIFF.
Check all indicators to see if root cause can be determined. If temperature remains below 475 o F, 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 repai red, 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 620 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 re medy 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 ki ln 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 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 721 Type of Malfunction: 

### Low Temperature in Baghouse

Possible Causes : Dilution air contro l failure, low process exhaust rate or temperature Type of Alarm: System alarm if temperature drops below

300 o F Critical alarm if temperature drops below

275 o F

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 sa fely 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, follo w 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 repai red, follow start-up procedures. 7. Complete all required paperwork

Steps Taken to Minimize Emissions:

1. Switch to bypass at critical alarm protects the integrit y of the control and

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

resolved. INCIDENT 822 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 not e 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 923 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 br eaks 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 pr acticable until compliance can be

assured if failure cannot be repaired in a timely manner. INCIDENT 1024 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 atte mpt to reinstall/restart; and

o Ensure all power and gas lines ar e functioning correctly and are

free from defect

 Suspend operations as soon as pr acticable until compliance can be
assured if failure cannot be repaired in a timely manner. INCIDENT 1125 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 prope rly Increase cleaning frequency Increase compressed air

pressure

Insufficient compressed air pr essure 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 troublesh ooting table from the Bundy manual for

ease of use. It is im portant 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 drawings27 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 tubeshee t 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 manufacturer28 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 applic ation 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 s upply 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 C onsult manufacturer or compressor

maintenance manual29 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 Inst all 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 ga sses Force turbulence in duct with

baffles

Thermocouple failed Replace and determine cause of

failure

Failure of cooling device Consult Manufacturer30 SYMPTOM CAUSE REMEDY

Moisture in Baghouse Insufficient pre-heating Ch eck hopper heater operation Run system with hot air only before starting process gas flow

System not purged at shut dow n 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 wate r 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 safe31 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 Veri fy 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 pipe32 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 bot h “start-up” and “shutdown”; You could explain here if you define “operating hours” differently fr om the time between the end of start-up and the beginning of shutdown- since by pass 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 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.

 The operator on duty should complete the In cident Report Form prior to the end of the shift or no later than 24 hours following th e 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. Reta in 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 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 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 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 should 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 Ma lfunction Plan in the semiannual excess emissions report (reports are due on January 31 and July 31 of each year).34

# APPENDIX AEXAMPLE REPORT FORMSBORAL BRICK Muskogee, OK

INCIDENT REPORT FORM

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 , 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 Minimi ze 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 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 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 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 BrickMuskogee, OKIncident/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-

# APPENDIX B-
LOG OF CHANGES TO SSMP

# Change Log for SSMP Revisions

DATE Changes (non-editorial) Initials