Continental Cement Company/Green America Recycling LLC Facility, Hannibal, Marion County, Missouri - Fact Sheet, August 2022

The Green America Recycling facility is located on about 3,500 acres in Hannibal. The facility name is Green America Recycling; however, the regulated activities are performed by both Continental Cement Co. and Green America Recycling LLC. Continental Cement operates a dry process cement kiln that produces clinker, the main ingredient in Portland cement. Continental Cement uses mainly pulverized coal to heat its kiln. To supplement its fuel needs, Continental Cement also uses non-hazardous waste fuels, such as used oil, and a variety of liquid and solid hazardous waste-derived fuels. Green America operates the hazardous waste fuel programs, which includes receiving, sampling, off-loading, storing and processing the liquid and solid hazardous wastes received at the facility. Most of the hazardous waste comes from off-site via truck and railcar. The liquid hazardous wastes are “blended” with other hazardous waste to achieve the desired fuel characteristics. The resulting wastes are stored in tanks until fed to the rotary kiln as liquid fuel.

The Green America facility is currently operating under a department-issued Missouri Hazardous Waste Management Facility Part I Permit, effective Nov. 18, 2019, and an EPA-issued Hazardous and Solid Waste Amendments Part II Permit, effective Aug. 31, 2021. Green America’s existing Hazardous Waste Part I Permit expires Nov. 18, 2029, and its Part II Permit expires Aug. 30, 2031.

Green America stores “characteristic” hazardous wastes, as well as various F-, K-, P-, and U- listed hazardous wastes. Green America and Continental Cement are currently permitted to operate:

• Four hazardous waste container storage areas, with a total maximum capacity of 817,250 gallons.
• Two hazardous waste containment buildings, with a total maximum capacity of 1,305 cubic yards.
• One cement kiln, with a treatment capacity of 14.55 short tons per hour.
• Five miscellaneous hazardous waste treatment units, with a combined capacity of 151,003 gallons per day.
• Six 25,000-gallon hazardous waste blending and storage tanks; four 75,000-gallon hazardous waste batch blending and supply tanks; and one 75-cubic-yard, dry hazardous waste solids storage tank.

Green America and Continental Cement are requesting the following permit modifications:

• Change Container Storage Area (CSA) #4, and add one container storage area, and a Direct Burn Pad, resulting in the total maximum storage capacity of 902,160 gallons.
• Add three miscellaneous treatment units, Hydrapulper #2, Drum Tipper Extruder System, and Quad Shredder #2.
• Add Direct Burn capabilities to the Cement Kiln system, resulting in a maximum treatment capacity of 24.09 tons per hour.
• Update all hazardous waste storage tank throughputs.
• Add piping to the CSA #3 Rail Yard Area, increasing Inspection Schedule.
• Partial closure of Tank #2, Feed Prep #1, and Feed Prep #1 Shredders #2 and #3.

On April 11, 2020, an explosion incident occurred at the facility in the former Ball Mill Building, adjacent to CSA #1, CSA #4, Feed Prep #1, and Feed Prep #2. Unpermitted processing of reactive waste in Quad Shredder #1 led to the explosion incident and subsequently halted all solids processing at the facility while a formal investigation commenced. In response to the explosion incident, Green America and Continental Cement are required to submit modifications for the following:

• Add Quad Shredder #1 as a miscellaneous treatment process, and identify Feed Prep #1 Shredders #1 and #4 as miscellaneous treatment units, resulting in a total maximum treatment capacity of 5,827 short tons per day.
• Change ventilation equipment in Feed Prep #1 and Feed Prep #2.
• Revise and update the Facility Scale and Traffic Patterns, Contingency Plan, Preparedness and Prevention Plan, Training Plan, Waste Analysis Plan, Closure Plan and Closure Cost Estimate.

Other administratively made modifications to the Part I Permit are the addition of a container- receiving process in CSA #4, and an added description for what constitutes an emergency situation notification requirement.

On June 1, 2021, Green America submitted a permit modification request to the department and EPA, requesting to: modify its existing hazardous waste permits to prevent disruption of ongoing waste management activities; enable Green America to respond to sudden changes in the quantities of wastes managed under the permits; and facilitate changes to protect human health and the environment. The department and EPA received the original modification request in its entirety on June 4, 2021. Green America and Continental Cement then revised and resubmitted the modification request on July 22, 2021, and submitted supplemental modifications and informational updates as follows:

• Aug. 4, 2021 - Revised sections 4, 5, and 6, and standard operating procedures.
• Aug. 27, 2021 - Supplemental EPA Method 1311 GAR Fuels Lab standard operating procedure.
• Sept. 24, 2021 - Supplemental Direct Burn operations (update received on May 5, 2020) and Comprehensive Performance Test Plan.
• Oct. 14, 2021 - Requested Rail Yard Piping changes in CSA #3.
• Jan. 31, 2022 - Supplemental Drum Piercer Ventilation.
• Feb. 1, 2022 - Revised Drum Tipper Extruder System.
• Feb. 2, 2022 - Revised Waste Analysis Plan.
• March 11, 2022 - Revised to operate both the existing Hydrapulper and the requested Hydrapulper #2.

At the end of the public comment period, the department and EPA will review all written comments and any comments given at the public hearing, if one was held. The department or EPA can change or deny the final permit modification(s) based on issues raised by the comments. The department and EPA will write a summary and response to all comments and explain how each was addressed in making the final decisions regarding the Part I and Part II Permit modifications. The department and EPA will issue final Part I and Part II Permit modification decisions once the public comment period has ended, all comments have been reviewed, and written responses have been prepared to address the comments.