Continental Cement Company, LLC - Executive Summary

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Continental Cement Company, LLC has prepared a more detailed executive summary that is attached to 
the front of the Risk Management Plan 
Executive Summary 
Risk Management Plan 
Predictive Filing 
Continental Cement Company, LLC 
Hannibal, Missouri 
1.    Accidental Release Prevention and Emergency Response Policies 
Continental Cement Company, L.L.C. (CCC) is strongly committed to protection of its employees, the public and the environment.  This commitment is inherent to a comprehensive accidental release prevention program that covers areas such as design, installation, operating procedures, maintenance and employee training associated with the processes at our facility.  It is CCC's policy to implement appropriate controls to prevent possible releases of regulated substances.  If such a release does occur, CCC has an emergency plan in place that is coordinated with the City of Hannibal Fire Department, the Hannibal Rural Fire Department and Marion-Ralls County Local Emergency Planni 
ng Committee (LEPC).  These local agencies provide highly trained emergency response personnel to control and mitigate the effects of the release.   
CCC receives a mixture of solvents used as alternate fuel materials to replace use of coal.  Compounds in the fuel mixture currently do not exceed the threshold quantity for any substance listed in 40 CFR 68.130.  Therefore, CCC is not required to submit a Risk Management Plan (RMP) under section 112 (r) of the Clean Air Act.  However, the potential to exceed these threshold quantities does exist.  If the concentration of substances in future alternative fuel material changes, threshold quantities can be exceeded.  CCC routinely tests and closely monitors the quantities of these substances.  Therefore, CCC is submitting this RMP to insure that we are in compliance and that our neighbors are aware of our worst case emergency scenario.   
2.    The Stationary Source and the Regulated Substances Handled 
CCC is a portland cement manufacturer loca 
ted approximately 3 miles south of downtown Hannibal, Missouri.  The original cement manufacturing facility was constructed in 1905.  The facility was continuously upgraded and enlarged to its current capacity.  The rotary cement kiln currently on-line was erected in 1966.  In 1986, CCC was granted interim status under the Resource Conservation and Recovery Act (RCRA) to operate an alternative fuel facility.  A mixture of various substances, regulated as hazardous waste primarily due to flammability, are received, stored and prepared for use as fuel in the cement kiln.  These alternative fuels burn cleaner than coal and serve as a direct replacement of coal.  The alternative fuels consist of spent products such as paints, inks, solvents, oil, and other flammable or combustible organic materials.   Both solid and liquid alternative fuels are received. 
CCC tests these fuels regularly to determine concentrations and quantities of regulated substances as defined by our permit.  Since testi 
ng began, CCC has found that only one test period showed a concentration of a regulated substance above the threshold quantity.  This period occurred three years ago with the fuel material present on-site for less than one week.  Ethyl ether was observed in the storage tanks at a level of 16,100 lbs.  The regulated inventory of Ethyl ether is 10,000 lbs.  Therefore, CCC has based this "Predictive Filing" Risk Management Plan on the storage and processing of a flammable material, ethyl ether, assuming that it may be received in the future above the threshold quantity.   
3.    The Worst Case Release Scenario(s) and the Alternative Release Scenario(s), including administrative controls and mitigation measures to limit the distances for each reported scenario 
To evaluate the worst case scenarios, CCC used the look-up tables and equations from Appendix D provided by the EPA in the "RMP Offsite Consequence Analysis Guidance" document.  Modeling was also performed using Dyadem RMP-PRO software 
.  Results from modeling were consistent with the EPA look-up tables.  The processes at CCC meet Program 1 eligibility requirements.  However, CCC has in place all the elements of Program 2.  Therefore, a worst-case release scenario and one alternative release scenario were analyzed.  The following paragraphs provide details of the chosen scenarios. 
The RMP is based upon Alternative Liquid Fuels Blending and Storage as a Program 2 process.  The worst case scenario considered for this process involves the flammable substance Ethyl Ether.  The quantity released in the scenario is assumed to be 50,000 lbs.  Passive mitigation considered in the scenario includes enclosures and sumps.  The tank area is roof covered and is provided with concrete containment large enough to hold the contents of the largest tank.  During the modeled worst case scenario, a leak occurs and the ethyl ether, from the tank, vaporizes.  A resulting vapor cloud explosion occurs having a distance to endpoint of 0.27  
miles.  This distance is less than the distance (0.51 miles) to the nearest public receptor.   
Under the alternative release scenario, a boiling liquid expanding vapor explosion (BLEVE) was chosen.  The BLEVE is from a 25,000-gallon storage tank of ethyl ether (flammable) and yielded a worst case impact distance 0.26 miles.  This distance is again less than the distance (0.51 miles) to the nearest public receptor.  
4.    The General Accidental Release Prevention Program and the Chemical-Specific Prevention Steps 
Our facility has taken all the necessary steps to comply with the accidental release prevention requirements set out under 40 CFR part 68.  This facility was designed and constructed utilizing guidance from the NFPA-58 Standard.  Our facility is also subject to EPCRA Section 302 notification requirements.    The following sections briefly describe the elements of the release prevention program that are in place at our site.  Our site is considered a stationary source. 
Safety Information 
CCC maintains a detailed record of safety information that describes the chemical hazards, operating parameters and equipment designs associated with all processes. 
Process Hazard Analysis 
Our facility conducts studies to ensure that hazards associated with our processes are identified and controlled efficiently.  The methodology used to carry out these analyses includes "what if" assessments followed by written response procedures.  The studies are undertaken by a team of qualified personnel with expertise in engineering, safety and process operations and are revalidated every year as part of our RCRA Contingency Plan.  Any findings related to the hazard analysis are addressed in a timely manner. 
Operating Procedures 
For the purposes of safely conducting activities within our covered processes, CCC maintains written operating procedures.  These procedures address various modes of operation such as initial startup, normal operations, temporary operations, emergency 
shutdown, emergency operations, normal shutdown and startup for annual maintenance activities.  The information is regularly reviewed and is readily accessible to operators involved in the processes. 
CCC has a comprehensive training program in place to ensure that all employees operating processes are competent in the operating procedures associated with these processes.  Refresher training is provided to all employees every year and more frequently as needed.  Documentation on training is maintained, reported to EPA/MDNR during quarterly inspections of the facility. 
Mechanical Integrity 
CCC carries out highly documented maintenance checks on process equipment to ensure proper operations.  Process equipment examined by these checks includes among others; storage tanks, piping systems, pressure relief and vent systems, emergency shutdown systems, controls and pumps.  Maintenance operations are carried out by qualified personnel with previous training in maintenance practices 
.  Furthermore, these personnel are offered specialized training as needed.  Any equipment deficiencies identified by the maintenance checks are corrected in a safe and timely manner. 
Management of Change 
Written procedures are in place at CCC to manage changes in alternative fuel materials, technology, equipment and procedures.  Process operators, maintenance personnel or any other employee whose job tasks are affected by a modification in process conditions are promptly made aware of and offered training to deal with the modification. 
Pre-startup Reviews 
Pre-start up safety reviews related to new processes and to modifications in established processes are conducted as a regular practice at CCC.  These reviews are conducted to confirm that construction, equipment, operating and maintenance procedures are suitable for safe startup prior to placing equipment into operation. 
Compliance Audits 
CCC conducts audits, using third party auditors, on a regular basis to determine whether the 
provisions set out under environmental regulations are being implemented.  These audits are carried out every year and any corrective actions required as a result of the audits are undertaken in a safe and prompt manner. 
Incident Investigation 
CCC promptly investigates any incident that has resulted in, or could reasonably result in a release of a regulated substance.  These investigations are undertaken to identify the situation leading to the incident as well as any corrective actions to prevent the release from reoccurring.  All reports are retained for a minimum of 5 years. 
Employee Participation 
CCC truly believes that process safety management and accident prevention is a team effort.  Company employees are strongly encouraged to express their views concerning accident prevention issues and to recommend improvements.  Safety committees are active and a program is in place to reward suggestions that improve safety, the environment and processes.  In addition, our employees have 
access to all information created as part of the facility's implementation of the RMP rule, including information resulting from process hazard analyses in particular. 
On occasion, our company hires contractors to conduct specialized maintenance and construction activities.  Prior to selecting a contractor, an evaluation of safety performance of the contractor is carried out.  CCC has a strict policy of informing the contractors of known potential hazards related the contractor's work and the processes.  Contractors are required to complete a Job/Project Safety Questionnaire and a Hazard Recognition Checklist prior to commencing work on the site.  Contractors are also informed of all the procedures for emergency response should an accidental release of a regulated substance occur. 
5. Five-year Accident History 
There have been no accidental releases of regulated substances at CCC within the last 5 years that have led to offsite deaths, injuries, or response or restoratio 
n activities for an exposure of an environmental receptor.     
6.    Emergency Response Plan 
CCC has coordinated an emergency response plan to deal with accidental releases of hazardous materials, fires and explosions.  The plan includes all aspects of emergency response including adequate first aid and medical treatment, evacuations, notification of local emergency response agencies and the public, as well as post-incident decontamination of affected areas. 
To ensure proper functioning, our emergency response equipment is inspected and serviced periodically.  In addition, the plan is promptly updated to reflect any pertinent changes taking place within our processes that would require a modified emergency response. 
Marion-Ralls County LEPC is the Local Emergency Planning Committee (LEPC) with which our emergency plan has been discussed and coordinated.  CCC is an active member of the LEPC. 
7. Planned Changes to Improve Safety 
CCC has planned several modifications to its process to imp 
rove safety.  These changes have the approval of EPA/MDNR.  CCC has prepared a schedule to raise six storage tanks located in the alternative liquid fuel blending and storage facility.  The purpose of raising the tanks is to allow for tank bottom inspection and enhanced leak detection.  Other process improvements include the installation of double mechanical seals on existing pumps and the replacement of fuel straining equipment with in-line grinding units.  These improvements reduce the occurrence of leaks and fugitive emissions from the process equipment.  
8. Certification Statement 
The undersigned certifies that to the best of my knowledge, information, and belief, formed after reasonable inquiry, the information submitted is true, accurate and complete. 
Name:        John W. White 
Title:        Vice President Operations 
Signature:    _____________________________ 
Date signed:    _____________________________
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