What Continental Cement Actually Does in Hannibal

This is not a typical factory. The kiln at 10107 Highway 79 South in Hannibal, Missouri burns hazardous waste as a fuel source while manufacturing Portland cement. That combination puts it in one of the most tightly regulated industrial categories in the United States.

• Continental Cement is a Delaware LLC operating in Missouri. Its Hannibal facility is classified as a “major source” of hazardous air pollutants under Section 112(a)(1) of the Clean Air Act, meaning it has the potential to emit ten or more tons per year of a single hazardous air pollutant, or twenty-five or more tons per year of combined hazardous air pollutants.
• Because the kiln burns hazardous waste, the facility is subject to the National Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors, known as the HWC MACT standard, codified at 40 C.F.R. Part 63, Subpart EEE. Missouri accepted delegation of these federal standards on February 28, 2019.
• The facility holds Title V Operating Permit OP2021-020, issued by the Missouri Department of Natural Resources on August 11, 2021, with an expiration date of August 11, 2026. That permit explicitly lists the facility’s coal mill, coal mill preheater, main stack, and alkali bypass baghouse as units subject to federal hazardous air pollutant standards.
• Emissions from the kiln are controlled by three baghouses: the main baghouse, the coal mill baghouse, and the alkali bypass baghouse. Each one is a large filter system designed to capture particulate matter before it exits into the surrounding air. Each one is legally required to run a continuous bag leak detection system that sounds an alarm if filter integrity is compromised.

Four Years of Silence: The Chronology of Inaction

The EPA’s investigation reconstructed a four-year window in which Continental Cement’s hazardous waste kiln operated with broken or misconfigured pollution alarms, failed emissions tests three times, and reported nothing to regulators. Here is that timeline in order.

• July 23, 2020: Continental Cement fails a particulate matter performance test, violating the federal standard at 40 C.F.R. § 63.1220(b)(7)(i). Missouri’s Department of Natural Resources is the first to document this failure and later provides this data to the EPA.
• May 20, 2021: Continental Cement fails a second particulate matter performance test. The Missouri DNR documents this violation as well. At this point, the company has failed two consecutive performance tests and is legally operating in violation of federal hazardous air pollutant emission standards.
• August 11, 2021: Missouri DNR issues Continental Cement Title V Operating Permit OP2021-020. The permit explicitly states the facility is subject to 40 C.F.R. Part 63, Subpart EEE, the very standards the company is already violating.
• July 18, 2022: Continental Cement fails a third particulate matter performance test. The alarm systems that are supposed to detect exactly these kinds of emissions problems have not triggered once across the entire test period.
• December 14-15, 2022: EPA Region 7 inspectors conduct a partial compliance inspection at the Hannibal facility. During this inspection, the facility’s environmental manager states on record that they cannot recall a single bag leak detection system alarm in the previous three years. No alarm records exist.
• December 14, 2023: The EPA sends a formal information request to Continental Cement under Section 114(a) of the Clean Air Act, demanding specific data on particulate matter emissions, control equipment, and bag leak detection system performance.
• March 1, 2024: Continental Cement’s own response to the EPA information request reveals the truth. The company’s internal evaluation found the main baghouse alarm had been set with a “truncated range” and the alkali bypass baghouse alarm was not responding to site conditions.
• May 6, 2024: The EPA issues a formal Finding of Violation to Continental Cement for violations of 40 C.F.R. Part 63, Subpart EEE.
• December 20, 2024: Continental Cement signs the Consent Agreement and Final Order. The penalty is set at $74,440. The EPA signs the same day. The Regional Administrator issues the Final Order on December 21, 2024.

The Non-Financial Ledger

Hannibal, Missouri is a small city on the western bank of the Mississippi River. It sits in Marion County. About 18,000 people live there. It is the kind of place where kids walk to school, where windows stay open in summer, where an industrial facility two miles from neighborhoods is just part of the skyline you learn not to think about.

Continental Cement’s kiln burns hazardous waste. That means it is not burning coal or natural gas alone; it is incinerating materials that have been classified as too dangerous for ordinary disposal. The filters, the baghouses, are the last line of defense between those combustion byproducts and the lungs of every person in the surrounding area. The bag leak detection systems are the alarms that tell the facility when those filters are failing.

For at least four years, those alarms were broken or misconfigured. The main baghouse alarm had been set with a “truncated range,” which is a technical way of saying the sensitivity dial had been turned so far down that it could not register what was actually happening inside the system. The alkali bypass baghouse alarm was simply not responding to site conditions at all. In other words: it was measuring nothing.

During those four years, Continental Cement failed three separate official performance tests measuring particulate matter. Particulate matter, especially the fine particles that come from industrial combustion processes, penetrates deep into lung tissue. It aggravates asthma. It causes inflammation. It worsens existing heart and lung conditions. Children, elderly residents, and anyone with a respiratory illness are most vulnerable. The families living closest to Highway 79 South did not consent to any of this.

The company’s environmental manager, speaking to EPA inspectors in December 2022, said they could not remember a single alarm in three years. Three years. At a facility burning hazardous waste. With federal law requiring continuous monitoring. That person’s job was environmental compliance, and they had nothing to report because the instruments designed to catch problems had been quietly rendered useless.

Continental Cement did not voluntarily disclose any of this. The EPA came to them. The inspection led to an information request. The information request forced the company’s hand. Only then, in March 2024, in a response to a legal demand, did Continental Cement confirm what its own internal evaluation found: both alarm systems had been failing for reasons the company identified but had not previously reported.

The children who ride Hannibal School District Bus 6 and Bus 14, the two aging diesel buses being replaced as part of the settlement, did not know they were breathing dirtier air than the law allows. They still do not know, because Continental Cement neither admits nor denies the underlying facts. That is the legal settlement’s language. It is also the reality those kids inherited: a company that broke the rules, paid less than seventy-five thousand dollars in fines, and walked away still operating.

Legal Receipts: What the Documents Actually Say

The EPA’s Consent Agreement and Final Order contains direct factual allegations. The following quotes are taken verbatim from the signed legal document, Docket No. CAA-07-2024-0077.

Eight Counts: What Continental Cement Is Accused of Violating

The EPA filed eight separate violation counts, organized into four paired categories. Each pair covers both the main baghouse and the alkali bypass baghouse systems. All eight counts reference violations of 40 C.F.R. § 63.4(a)(1) and 42 U.S.C. § 7412(i)(3)(A), the core federal hazardous air pollutant operating standard.

• Counts 1 and 2 (Main and Alkali Bypass Baghouses): Failure to continuously operate bag leak detection systems that meet federal specifications. The law requires these systems to run without interruption at all times. Continental Cement’s systems were not functioning correctly across the entire violation period.
• Counts 3 and 4 (Main and Alkali Bypass Baghouses): Failure to respond to alarm malfunctions within thirty minutes, and failure to take corrective action as required by the operating and maintenance plan. Because the systems never alarmed, corrective procedures were never started. The law treats the absence of alarms on a malfunctioning system as a trigger for response, not an excuse for inaction.
• Counts 5 and 6 (Main and Alkali Bypass Baghouses): Failure to notify the EPA Administrator when bag leak detection systems were malfunctioning more than five percent of the time in any six-month block period. This notification is required within thirty days of the end of each six-month period. Continental Cement submitted zero notifications between January 2020 and December 2023.
• Counts 7 and 8 (Main and Alkali Bypass Baghouses): Failure to comply with general operating requirements for hazardous waste combustors under 40 C.F.R. § 63.1206(c). Federal law states that any failure to comply with operating requirements is simultaneously a failure to ensure compliance with emission standards. These counts connect the monitoring failures directly to emission standard violations.

Societal Impact Mapping

Public Health

The violations center on the failure to monitor and control particulate matter from a hazardous waste burning kiln. The documented health consequences of uncontrolled particulate matter at industrial facilities like this one are established in the medical literature and in EPA regulatory records.

• Particulate matter from cement kilns burning hazardous waste can include fine particles (PM2.5) that penetrate deeply into lung tissue, bypassing the body’s natural filtration. Exposure at elevated levels contributes to asthma attacks, chronic obstructive pulmonary disease, and cardiovascular events. The populations most at risk are children, elderly residents, and anyone with a pre-existing respiratory condition.
• The Hannibal, Missouri facility sits at 10107 Highway 79 South in a community of approximately 18,000 people. Residents in the surrounding area had no way to know the monitoring systems designed to catch excess emissions were broken, because those systems were producing no alarms and no public-facing alerts.
• Continental Cement failed three official particulate matter performance tests across the violation period: July 2020, May 2021, and July 2022. Each failure means measured emissions exceeded the federal standard at 40 C.F.R. § 63.1220(b)(7)(i) for hazardous air pollutants on that test date. The monitoring failures made it impossible to know what was happening between test dates.
• The EPA’s consent agreement explicitly states the supplemental environmental project was designed “to reduce the adverse impact to public health and the environment to which the alleged violations contribute.” The EPA’s own framing acknowledges that the violations caused or contributed to public health harm, not merely administrative inconvenience.
• Children who ride Hannibal School District buses, including the two aging diesel buses being replaced under the settlement, are a direct part of the affected population. The replacement of those buses with propane-powered vehicles represents a tangible, if partial, acknowledgment that this community’s children were exposed to elevated pollution from multiple directions simultaneously.

Economic Inequality

The economic dimensions of this case follow a pattern common to industrial enforcement actions: the burden of the pollution falls on a working-class community with limited political power, while the financial consequences to the corporation are proportionally small.

• Hannibal, Missouri is a small Midwestern city where the median household income and economic base are not comparable to the resources of a Delaware LLC operating a heavy industrial facility. Residents do not have the legal infrastructure or financial capacity to independently monitor a hazardous waste kiln’s emissions compliance, making them entirely dependent on regulatory systems that Continental Cement was simultaneously undermining by failing to report malfunctions.
• The $74,440 civil penalty is the total financial price Continental Cement paid to the United States Treasury for four years of documented monitoring failures and three failed emissions tests. This is a fraction of the cost the company would have faced had all alleged violations been charged at the statutory maximum of $57,617 per day per violation. The EPA’s consent agreement structure allows companies to settle well below maximum exposure.
• The supplemental environmental project, while valuable, does not directly compensate Hannibal residents for four years of potentially elevated pollution exposure. The two propane school buses benefit children who ride those specific routes, but the broader community receives nothing beyond the knowledge that a fine was paid and a settlement signed.
• Continental Cement’s agreement to “neither admit nor deny” the factual allegations has a specific economic function: it eliminates the settled facts as automatic evidence in any future civil lawsuit by affected residents. Hannibal residents who might seek to hold the company accountable in civil court must re-prove facts that the EPA already documented and the company effectively resolved with a payment below six figures.
• The stipulated penalty structure in the consent agreement, where daily fines for failing to complete the school bus project range from $250 to $350 per day, demonstrates the scale of the financial asymmetry. A fine of $350 per day means Continental Cement could delay the school bus delivery for nearly a year and still pay less than what a single Hannibal family might spend on medical care for a child with asthma aggravated by industrial emissions.

The Cost of a Life Metric

What Now: Who Is Accountable and What You Can Do

The settlement is signed, but Continental Cement is still operating that kiln in Hannibal. The following are the responsible parties, oversight bodies, and actions that matter going forward.

Key Named Parties in This Case

• Timothy J. Noud, Vice President of Manufacturing, Central Region: The executive who signed the consent agreement on behalf of Continental Cement on December 20, 2024. He is listed as the company contact at tim.noud@continentalcement.com and at the facility address 10107 MO-79, Hannibal, MO 63401.
• David Cozad, Director, Enforcement and Compliance Assurance Division, EPA Region 7: The EPA official whose office brought and settled this enforcement action. He signed December 20, 2024.
• Antonette Palumbo, Office of Regional Counsel, EPA Region 7: The EPA attorney handling the case. Contact on record: palumbo.antonette@epa.gov.
• Meghan A. McCollister, Regional Administrator, EPA Region 7: The final authority who issued the binding Final Order on December 21, 2024.
• Luke Rodriguez, Compliance Officer, EPA Region 7: The EPA contact responsible for receiving the SEP Completion Report. Contact: rodriguez.luke@epa.gov.

Watchlist: Who Is Supposed to Be Watching

• EPA Region 7 (Lenexa, Kansas): The primary enforcing body under the Clean Air Act for this facility. Continental Cement’s compliance with the consent agreement, including the school bus delivery timeline, falls under Region 7’s authority to monitor and demand stipulated penalties for noncompliance.
• Missouri Department of Natural Resources (MO DNR): The state agency that holds delegation of 40 C.F.R. Part 63, Subpart EEE standards (accepted February 28, 2019) and issued the Title V Operating Permit. MO DNR documented two of the three failed performance tests before the EPA became involved.
• U.S. EPA Office of Inspector General: The independent watchdog within the EPA system. If you believe EPA enforcement of this settlement is inadequate or that future violations are being underreported, the OIG is the appropriate escalation point.
• Hannibal School District #60: The entity receiving the two propane school buses under the SEP. The district should be notified by residents if the buses are not delivered within fifteen months of December 21, 2024, the effective date of the Final Order.

What You Can Do

• Contact EPA Region 7 directly at 11201 Renner Boulevard, Lenexa, Kansas 66219, to request updates on Continental Cement’s SEP completion status and any ongoing compliance monitoring. The settlement requires Continental Cement to submit a completion report within eighteen months of the Final Order. That deadline falls in June 2026.
• Contact the Missouri Department of Natural Resources to request the complete inspection and performance test records for the Hannibal facility. These records are public under environmental disclosure laws and can reveal whether violations continued beyond the December 2023 cutoff covered by this settlement.
• Connect with local Hannibal environmental and community organizations. Residents living near Highway 79 South have the most at stake and the least institutional power. Local organizing can push for air quality monitoring by independent parties in the surrounding neighborhood, not just the company’s own instrumentation.
• Support mutual aid networks in Hannibal focused on families dealing with respiratory illness, asthma, and the downstream health costs that industrial pollution in lower-income communities disproportionately concentrates on those without access to quality healthcare. The EPA fine goes to the U.S. Treasury. Not one dollar goes directly to affected residents.
• Demand that your state and federal representatives require stronger whistleblower protections for facility-level environmental managers, so workers who know about malfunctioning alarm systems can report them without fear of retaliation before the EPA has to send inspectors to find out four years later.