Keystone Cement Company - Executive Summary |
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Keystone Cement operates a portland cement manufacturing operation on an approximate 850 acre parcel of land, located in Bath, PA. The facility operates 2 rotary kilns and associated raw and finished material processing operations in the production of portland cement. Raw material is mined on site and processed in preparation for use in the production of portland cement. The Keystone Cement facility also includes a fully permitted waste fuel storage tank facility. Waste fuel is received at the Keystone Cement faciity via tanker truck from off site and pumped into one of several waste fuel storage tanks. The tank farm facility consists of 4 storage tanks and associated ancillary equpment. Waste fuel is transferred to the cement kilns via aboveground pipeline. The Keystone Cement storage tanks are interconnected via pipelines and are also considered co-located within the tank farm and therefore, for purposes of compliance with 40 CFR Part 68, the Keystone Cement facility is consi dered to have one regulated process, the tank farm storage facility. The threshold quantity determination performed at the Keystone Cement facility used several conservative assumptions as outlined in the EPA RMP guidance document for warehousing (1/99). From this threshold determination, the facility developed a list of regulated substances that could potentially (although unlikely) be present in the regulated process above the applicable threshold quantity. An off-site consequence analysis was then performed in accordance with EPA guidance to determine the distances to the endpoints for each substance. From this analysis, it was determined that the facility did not have any public receptors within the distance to the endpoint for the worst case toxic release scenario. In addition, the facility has not had any reportable accidents under RMP and therefore, the facility is subject to the RMP Program 1 requirements. However, it should be noted that although the facility is subject to the Program 1 requirements of RMP (and is reporting accordingly), it has implemented an internal Risk Management Program using the Program 2 Prevention Program requirements as guide, to address all potential hazards and comply with the general duty clause of Section 112(r) of the Clean Air Act. In addition, Keystone Cement, as a RCRA interim status and permitted facility, has developed and implemented a PPC Plan in accordance with the Federal RCRA regulations at 40 CFR Parts 264 and 265. This plan is maintained on site and has been coordinated with the local emergency response agencies. |