## Startup, Shutdown and Malfunction Plan In Accordance with Brick and Structural Clay Products

National Emission Standard for Hazardous Air

Pollutants [SSMP for Brick MACT]

For



## BORAL BRICKS -

Salisbury Plant

DATE OF ORIGINAL PLAN: February 20, 2007

REVISION DATES May 7, 2007

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NOTE:

THIS DOCUMENT IS CONSIDERED



## COMPANY CONFIDENTIAL

AND SHALL NOT BE COPIED OR CARRIED OUTSIDE

OF BORAL WITHOUT MANAGEMENT APPROVAL

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Prepared by:

Susan J. Miller

Innovar Environmental Cary, NC

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Previous drafts of your SSMP for 5 y ears, including if the source is shut down or no longer subject to the MACT

********************************** ******************************* ************************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 (EITec), it is not intended to replace that document.

Supplemental information, such as detailed system parameters, can

be found in that document.

If, however, there is a discrepancy between a discussion of how the control operates between this docum ent and the E.I.Tec publication,

this document is the most current.

********************************** ************************** ********************1.0 INTRODUCTION

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

Boral Brick (Boral) is committed to ensur ing compliance with the Brick MACT and the requirements in the General Provisions of Part 63 (Subpart A), which apply to all sources subject to an industry-specific MACT (e.g., the Brick MACT ). As required by the Brick MACT, Boral will operate and maintain any affected source and any air pollution control equipment and monitoring equipm ent that is used to meet the standard in a manner consistent with safety and good air pollution control practices for minimizing emissions to the levels required by the re levant standards. That is, Boral will either

meet the emission standard or co mply with the startup, shut down, and malfunction plan.

Malfunctions will be corrected as soon as practicable after their occurrence in

accordance with this SSMP. To the extent that an unexpected event arises during a startup, shutdown, or malf unction, Boral will comply by minimizing emissions during such a startup, shutdown, and malfunction event consistent with safety and good air pollution control practices.

1.1 Facility/Operating Overview

Boral’s Salisbury plant has two operating tunnel kilns and is a major source of hazardous air pollutants (HAP). Tunnel Kiln 5 is not subject to the control requirements of the MACT because, as allowed by §63. 8390(d), “An existing tunnel kiln with a federally enforceable permit condition that restricts kiln operation to less than 9.07 Mg/hr (10 tph) of fired produc t on a 12-month rolling average basis is not subject to the requirements of this subpart.” Tunnel Kiln 6 is subject to the MACT control requirements.

Tunnel Kiln 6 is controlled by a dry injection fabric filter (DIFF) manufactured by E.I. Tec, L.P. This is equipped with two baghouse chamber s, termed Scrubber 1 and Scrubber 2 throughout this document. The flow from the kiln can be routed through a single chamber during a malfunction or if a ccess to one chamber is required for routine maintenance; however, this is not rout ine operation. The cleaning cycle of the baghouses is based on the pressure drop ac ross the baghouse system, with a back-up timed system to protect the integrity of the system.

The exhaust of Kiln 6 is regularly used as t he heat source to dry sawdust in the sawdust dryer. This exhaust, which comes in direct contact with the sawdust, is not subject to the control requirements of the Brick MACT. While other operating scenarios could be added later, the only operating scenario consi dered “regular” for this SSMP is the use ofboth chambers using, at a minimum, the lime feedrate designated for the process weight rate throughput of the current operation. 1

The DIFF has both a fresh and a recycled lime flow. During normal operation, both the fresh and recycled lime feed are used. The flow rate for each system can be documented through the measurem ent of the Hz reading for the respective auger. A correlation between the Hz reading and the lime fl ow rate is provided in the E.I. Tec manual. The readings for t he lime feed settings are est ablished during performance tests and the setting will be documented as part of the MACT compliance. 1

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

1 Based on conversations with NC DAQ, Boral Salisbury will be allowed to establish multiple minimum feed rate settings through performance testing. Each of these tests will be conducted as directed by the

state and will be documented in the OMMP.2.0 PURPOSE

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

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

minimize emissions

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

to the environment.

 Reduce reporting burdens associat ed with start-ups, shutdowns, and

malfunctions.

Regulatory Overview The general regulatory requirements cited below are addressed in our plan

 Section 63.6(e)(3) of Subpart A, Gener al Provisions and §63.8420(c) of Subpart JJJJJ requires that we develop and impl ement a Startup, Shutdown, and Malfunction Plan for operations used to co mply with the Brick and Structural Clay

Products MACT.

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

describe what corrective action we will take if a malfunction occurs at an affected process, air pollution control or monitoring equipment.

 In addition to the requirem ents to develop and implemen t a written plan, we are also required to:

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

actions we took to minimize emissions during the event.

– Submit reports if procedures we took during the event are not consistent with the procedures we put in the plan and excess emissions occurred.

– Revise the Malfunction Plan if a malfunction occurs that has not been described here or procedures for corrective action have not been adequately described.

– Update the plan if requested by EPA or the appropriate State or Local Air Pollution Control Authority.

********************************** ******************************* ******************** Defining MACT Malfunctions

Boral Salisbury may experience malfunc tion incidents. Please be aware that our operators may use a different definition of the term “malfunction” than the regulatory definition. We will be tracking each “incident” where a piece of equipment fails to oper ate as expected and will determine

whether or not this event constitu tes a malfunction under the MACT as part of this process.For the remainder of this docum ent, we will use the term “MACT

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

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

In general, the focus of our procedures is to protect both the inte grity of the control system and reduce the emissions to the atmo sphere. Boral believes that both are critical to ensuring the long-term emission re duction ability of the system. In addition, the safety of plant personnel and visi tors is always the first priority.

To balance these, Boral follows the following general principles:

 The exhaust from the kiln is vented through the control device when the stack temperature is within the acceptable range. Venting at too low a temperature could cause moisture to enter the syst em and cause the lime to solidify and create corrosion in the system . Venti ng 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 temper ature ranges.]

 The exhaust must have a clear path though the system for the exhaust to be vented through the control. Exhausting when there is no clear path (e.g., dampers closed to the baghouse) would damage the control, creating potential safety issues and potentially damaging the integrity of the cl eaning process.

 The E.I.Tec system is equipped with tw o separate chambers. When possible during an incident/malfunction, Boral will co ntinue to vent as much exhaust as possible through one of the chambers of t he baghouse. Boral will ensure that doing so does not adversely impact worker sa fety or the integrit y of the system. Venting through one of the chambers, even if there is no lime flow, will result is

some level of emission reduction.

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

3.1 STARTUP PROCEDURES

This section describes the st art-up procedures for the #6 k iln and the E.I. Tec DIFF. The E.I. Tec DIFF was brought online while the kiln is in operation (when the temperature of the flue gas is in the right te mperature range).

The standard automated start- up procedure for the kiln and control device is described below. The same procedure is followed for each start-up of the cont rol/kiln. However, some steps may be skipped if they have previously been completed.

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

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

3. Start gas fan.

4. Push start-button on the display onto the control panel.

- Main switch on control panel to position “ON”.

- Press “Reset” on control panel.- Switch on gas fan on control panel.

- Switch on scrubber 1 on control panel.

- Switch on scrubber 2 on control panel.

Steps to Minimize Emissions

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

have been corrected. This ens ures that the control can only operate when all systems are operating properly, which ensures minimized emissions.

 In order to minimize emissions , the fresh lime metering screw will be set at or above the minimum level established during the performance test for the current throughput, 2 as airflow allows, for a short period during start-up to ensure that the baghouses fill with lime as quickly as possible.

3.2 SHUTDOWN PROCEDURES

There is generally a low need for shutting down the control and/or the kiln. As stated previously, the kiln tends to remain in operat ion. If the control and/or the kiln need to be stopped, the following general princi ples impact the procedures.

 Unless a safety issue or control device integrity issue occurs, the kiln will continue to vent through the control dev ice (or a portion of the control device)

until the exhaust reaches the low temperature set point.

 If control device is operational, product feed into the kiln will be stopped before the lime feed into the DIFF is stopped (If kiln shutdown is required).

 Unless safety to Boral personnel and visitors or ongoing integrity of the control is threatened, all procedures will be aimed at minimizing avoidable emissions of HAP to the atmosphere. Maintaining the integrity of the system is critical to quickly returning the system to operational.

 If the control must be taken offline fo r routine maintenance, the time will be documented as being part of the time allowed under the Routine Maintenance Bypass Allowance in Boral’s Title V Operating Permit.

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

described below.

Complete Shut-down only:

- Switch off scrubber 1 on control panel.

- Switch off scrubber 2 on control panel.

- Switch off gas fan on control panel.

- Main switch on control panel to position “OFF”.

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

2 See Appendix C of Salisbury’s MACT OMMPMaintenance/ Malfunction Shut-down:

- Switch off scrubber 1 on control panel.

- Switch off scrubber 2 on control panel.

- System automatically goes to by-pass.

Steps to Minimize Emissions

 Unless there is a concern about the sa fety of personnel or maintaining the integrity of the control, the kiln will continue to vent through the control device until the exhaust reaches the low temperatur e set point. This ensures that the exhaust will be cleaned as long as the ra w gas may contain harmful emissions.3.3 MALFUNCTION PROCEDURES

This section describes the overall approach to identifying the cause of a malfunction incident, correcting it, and dete rmining whether the incident meets the definition of a

“MACT malfunction.” It shoul d be noted that Boral Brick has a responsibility to assure worker safety and to comply with all OSHA and MSHA safety require ments. This will often affect the approach that must be taken to rectify a malfunction si tuation. Boral will work to minimize emissions at all times, while ensuring all other health and safety requirements are also met.

Boral’s approach to minimizing emissions du ring a malfunction incident is to review the potential to minimize the two primary factor s that influence overa ll emissions: duration

and concentration of the emissions.

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

of time the DIFF is offline, Boral will:

a. Respond as quickly as possible to each AL ARM (e.g., within 30 minutes of the first alarm). b. Maintain spare parts list ed in the MACT Operation, Maintenance, and Monitoring Plan (MACT OMMP).

c. Personnel, trained in alarm mode and respon se, are onsite at all times the kiln and control are in operation

. Additional trained staff members are on-call 24 hours per day.

2. Minimize the amount of emissions that are vented when the control device is not fully operational

. To ensure that the amount of emissions that are vented to the atmosphere are minimized, Boral will (f or each incident) determine if it is possible to continue to vent through the c ontrol device, or part of the control device while the incident/MACT malfunction is being addressed (e.g., venting through the baghouse, even if lime flow has stopped; venting through one chamber while the other is being maintained). Operation in a “semi controlled” st ate is discussed in

more detail below.

Boral will either minimize t he length of the downt ime or the amount of emissions, or both, to the extent practic able during any MACT malfunction. It is important to note that switching to uncontrolled bypass fo r a short amount of time could actually

minimize the total amount of emissions exhausted to the atmosphere. If the control were not bypassed, the control and/or kiln would need to be cooled over many hours (or days) and then restarted, which could result overall in more

emissions.

In addition, Boral has the potential to run in a “semi-controlled” state during periods where uncontrolled emissions are not prohibi ted under the Brick MACT. This “semicontrolled” condition would allow exhaust, or a portion of the exhaust, to flow through the baghouses, where some lime caking would still exist on the bags. This allows Boralto minimize emissions due to the malfunction (or routine ma intenance discussed in the OMMP). By opting for “semi- controlled” operation whenever possible, Boral is meeting the General Duty clause to reduce emissions.

The following sections include lists of spec ific procedures to be followed when an incident occurs that could potentially be co nsidered a MACT malfunction under the Brick

MACT. This list is based on a list of condi tions that could have a direct impact on emissions, either immediately or if a situation is not corrected in sufficient time. It does

not include other incid ents that Boral reviews periodica lly to ensure that the control device is operating properly. Therefore, it is not identic al to the list included in the

E.I.Tec manual.

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

1. Shutdown Alarm – An alarm that is triggered by an event that puts personnel safety or equipment integrity in danger. 2. Warning Alarm – An alarm that is triggered by an event that needs to be known by the operator but has no i mmediate impact on any other system components. Also an alarm that is tri ggered by an event that affects other components in the system but does not indicate current personnel equipment danger.

A shutdown alarm will immediately cause t he system to go into bypass and shutdown. This alarm is only triggered when either pers onnel are in danger or the integrity of the system could be compromised. Protecting th e integrity of the system will ensure a more rapid return to normal operation of the contro l. In general, there is at least one warning alarm that would indicate pr oblems before they would rise to the level of a shutdown

alarm.

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

to assess whether the incident ma y be considered a MACT malfunction.

The incidents/potential MACT malfunctions that have been identifi ed are listed below and detailed on the following pages.

Incident

# Condition

1 Pressure drop across baghouses too high 2 Pressure drop across baghouse too low 3 Lime flow too low and/or stopped (i.e., no “freeflowing lime” 4 Airflow too low (could cause lime to not remain suspended)

5 Visible emissions from stack6 High temperature in baghouse inlet 7 Low temperature in baghouse inlet 8 High level alarm in hopper 9 Reduced compressed air pressure 10 Mechanical equipment failure (to be used for key equipment failures before above conditions occur) 11 Loss of power or gas

12 Acts of GodType of Malfunction: 

### Pressure Drop Higher Than Acceptable Range

Possible Causes : Inefficient cleaning cycle in baghouse (e.g., timing or inefficient compressed air); faul ty pressure indicator, reentrainment of lime; low fan motor amperage Type of Alarm: Warning Alarm

Steps Taken to Correct Problem:

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

2. If it can be determined that the high pressure reading is in error or only in one chamber, determine if exhaust can still safely vent through one or both baghouse chambers. If so, continue to vent through baghouse. If not, switch to bypass

mode.

3. Depending on root cause (see Appendix A), follow remedy steps listed below. 4. If malfunction cannot be repaired in 4 hours , notify management to evaluate whether change in kiln operation is warrant ed or if other actions are warranted. 5. Once the malfunctioning equipm ent has been repaired, follow start-up procedures. 6. Complete all required paperwork.

Steps Taken to Minimize Emissions:

1. Since high pressure drop most likel y indicates excessive lime on the bags, exhaust will continue to flow through one or both chambers of the system unless it will cause a danger to personnel or the equipment. This will ensure that the maximum possible emission reduction is still achieved during the incident. 2. Boral will maintain spare parts reco mmended by E.I.Tec to ensure parts most likely to require replac ement are available. INCIDENT 1-Type of Malfunction: 

### Pressure Drop Across Baghouse Lower Than Acceptable Range

Possible Causes : Cleaning cycle too frequent; cleaning cycle based on time rather than pressure drop; power failure; exhaust

Fan Failure

Steps Taken to Correct Problem:

1. Stop all bag cleaning (i.e., turn off time -based cleaning as backup to pressure-drop based cleaning) 2. Determine if exhaust can still safely v ent through one or more baghouse modules. If so, continue to vent through baghouse. If not, switch to bypass mode

3. Check all indicators to see if root cause can be determined. 4. Depending on root cause, follow remedy steps listed in the E.I. Tec table (See Appendix A) 5. If malfunction cannot be repaired in 4 hours, notify management to evaluate whether change in kiln oper ation is warranted. 6. Once the incident has been repaired, follow start-up procedures. Temporarily increase lime flow, if warranted, to re-establis h lime build-up on bags. 7. Complete all required paperwork

Steps Taken to Minimize Emissions:

1. Stopping bag cleaning while determini ng cause will ensure the build-up on the bags is not further reduced. 2. Continuing to flow the exhaust through one or more c hambers of the control (if possible) will provide some amount of emission reduction. INCIDENT 2-Type of Malfunction: 

### Limeflow Too Low and/or Stopped

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

Steps Taken to Correct Problem:

1. Check for lime in the hopper 2. Determine if exhaust can still safely v ent through one or more chambers of baghouse. If so, continue to vent thr ough baghouse. If not, switch to bypass

mode. 3. Discontinue bag cleaning until flow has been re-established. 4. Identify and remove blockage, if present. 5. If malfunction cannot be repaired in 4 hours , notify management to evaluate whether change in kiln operation is warranted.

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

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

Steps Taken to Minimize Emissions:

1. Since there will continue to be lime bu ild-up on the bags, exhaust will continue to flow through one or both baghouse chambers unless it will cause a danger to personnel or the equipment. This will ensure that the maximum possible emission reduction is still achieved during the incident. 2. Discontinuing bag cleaning during this in cident will ensure that lime remains on the bags to provide the maximu m amount of cleaning possible. INCIDENT 3Type of Malfunction: 

### Airflow Through System Too Low

Possible Causes : Exhaust Fan Failure

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 chambers of the baghouse. If so, continue to vent thr ough baghouse. If not, switch to bypass

mode. 3. Discontinue baghouse cleaning if lime flow has stopped. 4. Depending on root cause, follow rem edy steps listed in E.I.Tec Manual (see Appendix A) 5. If malfunction cannot be repaired in 4 hours , notify management to evaluate whether change in kiln operation is warranted. 6. Once the incident has been repaired, follow start-up procedures. Increase lime

feed for limited time to re-establish build-up on filters, if necessary 7. Complete all required paperwork

Taken to Minimize Emissions:

While reduced airflow may cause the syst em to automatically discontinue limefeed (to prevent lime blockages caus ed by insufficient flow to maintain the lime in the air stream), there will still be lime caked on the baghouses . Therefore, exhaust will continue to flow through the system unless it will cause a danger to personnel or the equipment. This will ensure that the maximum possible emission reduction is still achieved during the incident. INCIDENT 4Type of Malfunction: 

### Visible Emissions from Stack

Possible Causes : Bag breakage; improper duct balancing; improper seal at tube seat; insufficient filter cake Type of Alarm: None- determined from visible observation

Steps Taken to Correct Problem:

1. Check all monitors/indicators to see if root cause can be determined. 2. If problem is limited to one chamber, continue to flow through one chamber, continue this flow while fixing problem. If the problem allows flowthe issue is other than bag breakage, det ermine if exhaust can still safely vent through baghouse while work continues to fix the malfunctioning equipment. If so, continue to vent through baghouse. If not, switch to bypass mode. 3. Depending on root cause, fo llow remedy steps listed in E.I.Tec table (included in Appendix A). 4. If malfunction cannot be repaired in 4 hours , notify management to evaluate whether change in kiln operation is warranted. 5. Once the incident has been repai red, follow start-up procedures. 6. Complete all required paperwork

Steps Taken to Minimize Emissions:

1. Boral will seek to identify whether a single bag or a limited number of bags is causing the visible emissions (this woul d most often be the case) as soon as practicable. Then, those bag(s) woul d be closed or blinded and the exhaust will be vented through the remaining modules. INCIDENT 5Type of Malfunction: 

### High Temperature in Baghouse Inlet

Possible Causes : Dampers stuck on dilution vent, raw gas from Kiln
temperature. Type of Alarm: Warning first; switches to bypass if temperature

reaches 480 o F

Steps Taken to Correct Problem:

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

the DIFF.

2. Check all indicators to see if root cause can be determined. 3. If temperature remains below 500 o F, continue to vent through baghouse, unless there is a personnel safety or an additio nal control device integrity issue. 4. Depending on root cause, follow remedy steps listed in E.I.Tec table (reproduced in Appendix A). 5. If malfunction cannot be repaired in 4 hours , notify management to evaluate whether change in kiln operation is warranted. 6. Once the incident has been repai red, follow start-up procedures. 7. Complete all required paperwork

Steps Taken to Minimize Emissions:

1. System integrity maintained to expedite return to normal operation 2. Bypass stopped as soon as it is po ssible to safely vent through system. INCIDENT 6Type of Malfunction: 

### Low Temperature in Baghouse

Possible Causes : Raw gas temperature too low.

Steps Taken to Correct Problem:

1. Check all indicators to see if root cause can be determined. 2. Verify that lime is flowing to control device. 3. Determine if exhaust can still safely v ent through one or both chambers of the baghouse. If so, continue to vent thr ough baghouse. If not, switch to bypass

mode. 4. Depending on root cause, follow rem edy steps listed in E.I.Tec table (see Appendix A). 5. If malfunction cannot be repaired in 4 hours , notify management to evaluate whether change in kiln operation is warranted. 6. Once the incident has been repai red, follow start-up procedures. 7. Complete all required paperwork

Steps Taken to Minimize Emissions:

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

raw gas. INCIDENT 7Type of Malfunction: 

### High Level Alarm in Hopper

Possible Causes : Bridging in hopper (caused by improper air loosening, conveyor plugged); indicator malfunction. Type of Alarm:

Steps Taken to Correct Problem:

1. Check all indicators to see if root cause can be determined. 2. Verify that lime is flowing to control device 3. Determine if exhaust can still safely vent through one or both chambers of baghouse. If so, continue to vent thr ough baghouse. If not, switch to bypass

mode. 4. Depending on root cause, follow remedy steps listed in E.I. Tec Manual (see table in Appendix A). Going to need to refe rence something else- section 5 or 10- or repeat information here. 5. If malfunction cannot be repaired in 4 hours , notify management to evaluate whether change in kiln operation is warranted. 6. Once the incident has been repai red, follow start-up procedures. 7. Complete all required paperwork

Steps Taken to Minimize Emissions:

1. Boral will identify which hopper is high. The waste discharge system will run continuously until the excess lime has been removed from the cone. Emissions

will not have increased. INCIDENT 8Type of Malfunction: 

### Reduced Compressed Air Pressure

Possible Causes : Compressed air consumption too high; restriction in piping; air dryer plugged; compressor not operating properly Type of Alarm : Initial warning alarm then shut down before level necessary to shutdown system efficiently is reached.

Steps Taken to Correct Problem:

1. Check all indicators to see if root cause can be determined. 2. Determine if exhaust can still safely v ent through one or both chambers of the baghouse. If so, continue to vent th rough baghouse. If not, switch to bypass

mode. 3. Depending on root cause, follow rem edy steps listed in E.I.Tec Manual (see Appendix A). 4. If malfunction cannot be repaired in 4 hours , notify management to evaluate whether change in kiln operation is warranted. 5. Once the incident has been repai red, follow start-up procedures. 6. Complete all required paperwork

Steps Taken to Minimize Emissions:

1. Boral will identify the r oot cause of the problem. If cause is determined to be compressor related, Boral will provi de portable compressor to replace or supplement air supply. INCIDENT 9Type of Malfunction: 

### Mechanical Equipment Failure

Possible Causes : Equipment Malfunction Type of Alarm: Warning Ala rm and/or Shutdown Alarm

Steps Taken to Correct Problem:

1. Ensure that the situation has become stable and the hazards have been cleared before proceeding further. 2. Confirm the system status and note wh ich equipment is o ff-line or otherwise impaired. 3. Notify appropriate maintenance or other responsible personnel. 4. Respond to correct or repair the malf unction in a safe, efficient and timely manner as soon as it is practicable. 5. Follow procedures i ndicated in Appendix A.

Steps Taken to Minimize Emissions: INCIDENT 10Type of Malfunction: 

### Loss of Power or Gas

General Steps Taken to Correct Malfunction and Reduce Emissions

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

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

 Notify appropriate maintenance or other responsible personnel.

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

 Call power company if power failure seem s plant-wide; if not, trace power failure from equipment to power source;

o Check source of gas;

o Trace gas line from equipment to the source and determine whether any leaks or breaks in line exist; and

o Repair any breaks or leaks that are found in the utility system at the facility.

 Suspend operations as soon as practic able until compliance can be assured if failure cannot be repaired in a timely manner. INCIDENT 11Type of Malfunction: 

### Acts of God

General Steps Taken to Correct Malfunction and Reduce Emissions

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

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

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

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

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

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

defect

 Suspend operations as soon as practic able until compliance can be assured if failure cannot be repaired in a timely manner. INCIDENT 124.0 RECORDKEEPING REQUIREMENTS

We will track all start-up and shutdown events. Operating hours are defined as the time between the end of start-up and t he beginning of shutdown.

WHEN A POTENTIAL MALFUNCTION HAPPENS

 For all incidents that could potentially be seen as a MACT Malfunction, an Incident Report Form will be completed.

 The completed Incident Report Form shoul d be reviewed and signed by the Shift Supervisor and any additi onal comments added.

ACTIONS

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

 If the problem cannot be co rrected within a reasonable amount of time after detection (e.g., 4 hours), notify the Shift Supervisor. This does not mean that kiln operation will, or should, be affected. However, additional discussions should be

held.

 The operator 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)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 Section 5-7 for an example form);

o Whether any excess emissions and/or parameter moni toring exceedances are believed to have occurred during the malfunction (§63.10(d)(5)(ii));

and

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

 If the actions taken during a malfunction we re not consistent with this Malfunction Plan, because the plan did not address the type of malfunction that occurred

and/or the actions taken were not included 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 Malf unction Plan in the semiannual excess emissions report (within 60 days following the end of each 6-month period).

# APPENDIX AE.I.TEC TROUBLESHOOTING GUIDE

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

ascertaining and correcting incidents where the control is not operating properly. It is reproduced in its entirety for convenience and ease of use.

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

this manual because it is our determination that these events do not have the potential to be a “MACT Malfunction.” Many of thes e events could impact the efficiency of this control (i.e., energy efficiency), they do not have the potential to directly impact MACT requirements.(insert Section 4.3 here)

# APPENDIX BEXAMPLE REPORT FORMSBORAL BRICK Salisbury, NC

INCIDENT REPORT

MALFUNCTIONING DEVICE:

_______________ _________

DATE OF INCIDENT:

____________ __________________

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

Determination that incident w as not a malfunction under MACT

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

If not, why? {explain how you determined that this was not a malfunction under MACT- for example- emissi ons did not increase as a result of this incident}

Signature: ______

_____________ Date: _________________________

FOR MACT MALFUNCTIONS ONLY (If determination has yet to be made, complete this information)

Duration : (Estimated) Start

Time:

End Time:

Duration:

Estimate of excess emissions or parameter monitoring exceedances

1. Was this event included in the SSM plan? 

## Y / N

2. Were the procedures in SSM plan followed? 

## Y / N

 If the answer to both questions above is YES , skip to end of form, sign, and stop. List malfunction in semi-annual report.

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

## Immediate reporting required. SEE SECTION 5 OF BORAL’s

SSMP TRACKING
NUMBER: ________BORAL BRICK Salisbury, NC

INCIDENT REPORT

3. Action Taken to Correct the Problem

4. Actions Taken to Minimi ze Emissions During Problem

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

Signature: ______

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

unless incident is determined to NO T be a malfunction under the MACT: [NOTE:

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

START-UP AND SHUTDOWN LOG

DATE Begin “Start-up” End “Start-up” Begin “Shutdown” 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 BrickSalisbury, NCIncident/Malfunction TrackingDateTrackingNumberWas theIncident aMalfunction?If YES, wasthe SMMPfollowed?If SSMP not followed....Who completedthis log?SeeNote1Was 2nddayreport calledin or faxed?Was 7thdayreport mailedWas SSMPmodified?1Add a reference letter to this column, ifyou need to add additional information below:abcd-BORAL Brick Salisbury, NC



# APPENDIX C

LOG OF CHANGES TO SSMPBORAL Brick Salisbury, NC



# Change Log for SSMP Revisions

DATE Changes (non-editorial) Initials 3/9/07 Update process steps, add comments and questions

4/30/07 Revised to referenc e potential for multiple levels for “minimum lime flow,” remove any blanks or notes, incorporate revisions to E.I. Tec operating manual.