Southeastern Adhesives Company- Lenoir, NC Plant - Executive Summary |
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68.155 EXECUTIVE SUMMARY Southeastern Adhesives Company has prepared and is submitting this Risk Management Plan according to Federal Environmental Protection Agency regulation 40 CFR 68.150 through 68.190, assessing regulated substances occurring in amounts above the EPA threshold quantities and the hazardous processes involving these substances. These regulations mandate the investigation of potential accident scenarios which could effect the surrounding population and environment as determined by published EPA regulations, guidelines and guidance materials. The scenarios prescribed for investigation include both a worst-case and an alternative release which could possible occur at the Southeastern Adhesives (SEACO) facilities. a)SEACO, under its present Senior Management, has adopted a pro-active approach to chemical safety by instituting a chemical accidental release policy governing all chemicals present at our stationary sources. This policy addresses the safe handling and st orage of all process chemicals and products, as well as, chemicals used in the day to day operations of our facility and allows for the monitoring of safe practices, procedures and conditions with daily visual inspections of all process and storage areas. If an emergency situation should ever occur, SEACO's emergency response plan would be initiated. Designated, trained response teams and individuals would proceed with appropriate actions which are spelled out in the emergency plan, thus ensuring the safety of its employees, surrounding neighbors, and environment. Both SEACO's "Accidental Release Plan" and "Emergency Response Plan" are contained in its general Programs and Policies Manual. b) SEACO owns and operates two stationary sources which are required to submit Risk Management Plans to the EPA, they are similar in process: 1) SEACO 815-D Virginia St., SW PO Box 2070 Lenoir, NC 28645 2) SEACO 126 Reservoir Road Ridgeway, VA 24148 This RMP*Submit plan covers SEACO in Lenoir, NC only. The SEACO facility in Lenoir, NC manufactures many water based adhesive products including urea formaldehyde (UF) resins. Both formaldehyde and urea are stored in bulk. We use a batch process where these chemicals along with others are measured by weight and charged to one of two 3,000 gallon reactors. Through a series of pH and temperature adjustments and controls, the final UF product is obtained. All process steps are monitored for proper operation and all are under the constant supervision of trained personnel. These resins are then stored in bulk and shipped in appropriate containers. To the best of our understanding the facilities are compliant with all applic able State and Federal Regulations. SEACO has determined from the substances listed pursuant to section 112(r)(3) of the Clean Air Act and its amendment SS68.130 List of Regulated Toxic Substances and Their Threshold Quantities for Accidental Release Prevention that it houses only one regulated substance in quantities at or above the given "threshold quantities": FORMALDEHYDE, held in maximum quantity (at any one time) of 84,500 pounds. at the Lenoir, NC plant (stationary source). The formaldehyde is stored as a liquid in a 50% formaldehyde, 1% methanol, 49% water solution at 50 - 65 degrees centigrade and is contained in a 18,000 gallon double clad carbon / stainless steel storage tank which is held to below maximum capacity by Administrative controls to safeguard against overfilling. This tank is surrounded by a dike / sump passive mitigation system. c) The worst-case release scenario would be triggered by rupture of the main storage tank, potentially resulting in a spill of approximately 84,500 pounds or 18,000 gallons 50% formaldehyde into an existing diked area (passive mitigation applied) with a capacity of greater than 60,000 gallons or greater than 500,000 lbs. (within this diked area). In the event of such a large scale spill, the dike is sufficiently large to contain the entire contents of a worst-case scenario spill in a relatively small surface area pool and the formaldehyde would be recovered by pumping into tanker trucks or holding tanks and held until the main storage unit was repaired or replaced. According to the EPA's Off-site Consequence Analysis Guidance, (a document provided by the federal EPA to assist industry in the preparation of their RMP) such an accident might warrant evacuation of the stationary source and notification of appropriate emergency response agencies who are designated to respond to potential crisis situations. The following Worst-case scenario parameters used to determine data included in this RMP: -84,500 lbs. fo rmaldehyde released (50% by weight concentration in water, <18,000 gallons contained in one 18,000 gallon tank @ 50-65 degrees Centigrade. When released into ambient conditions; formaldehyde polymerizes to paraformaldehyde at less than 50 degrees C thus reducing its evaporation rate greatly) -released at once, on ground level ( 40 CFR 68.22(d), Exhibit 1 and Chapter 3; OCA Guidance) -released over 10 minutes, ( Chapter 3, page 15,16,17; OCA Guidance) -passive mitigation, dikes and sumps limiting pool surface area -wind speed (1.5 m/sec) and atmospheric conditions ("F" Stability) ( Chapter 1, page 3; OCA Guidance) -dense gas due to formula weight -urban topography (40 CFR 68.22(e)) -formulas as per Chapter 3 and Appendix D; OCA Guidance) -temperature, liquid density and vapor pressure values obtained from supplier. -appropriate tables (Chapter 4 & 5, OCA Guidance) -all data calculated for 50% formaldehyde in water solution (with 1% metha nol) as per formulas Chapter 3 and Appendix D, OCA Guidance, based on temperature and vapor pressure data obtained from supplier -residential receptors estimated using actual residence counts times estimated person per household, southern region - (ST-96-20R "Estimates of Housing Units, Households, Households by Age of Household and Persons per Household", Population Estimates Program, Population Division, US Bureau of the Census as of 7-1-96, Internet date 7-7-97, revised 8-21-97.) SEACO management has chosen as its alternative scenario the possibility of a runaway reaction during the UF batch process, as this is more likely than the Worst Case Scenario above and could impact off-site, public receptors. This scenario is unlikely as the reaction process is constantly monitored by trained, experienced personnel during the critical stages. A run-away reaction would not result in the release of 100% of the 50% formaldehyde solution charged to the reaction. The reaction of formaldehyde with urea produces a large amount of heat and causes the acidity of the reaction mixture to increase (lower pH). Both the heat and the lower pH add to the instability of the reaction. Therefore, as the reaction proceeds and more formaldehyde reacts with urea, the process becomes more unstable and the possibility of a runaway reaction increases but the availability of unreacted formaldehyde decreases. It is also unlikely that all the reaction mixture would escape from the large vessel through its relatively small (24 inch) mouth, as the reaction vessel is never intentionally filled to capacity. The exact amount of unreacted formaldehyde released is impossible to determine; therefore, based upon reaction kinetics, vessel size and experience, a quantity of half (50% x 20,000lbs) of the (50%) formaldehyde/water solution charged to the reaction was used to conduct calculations as this would be a generous estimate of a formaldehyde released from such a runaway reaction. Any process reaction problems would be mitigated by the production building itself, as all reaction spills, etc. would be contained within this building. According to EPA's OCA Guidance document, releases under this scenario could affect off-site, public receptors [as prescribed by 40CFR68.28(b)(1)(ii)]. The following Alternative-case parameters were used in determining the data included in this RMP: -half quantity (0.5 X 20,000 lbs) of 50% formaldehyde solution [(50% formaldehyde, 1% methanol, and 49% water) at 50-65C] charged for reaction was used to figure quantity released (see above paragraph) -reaction at 90 degrees centigrade, vapor pressure unknown, assume total release over 10 minutes (Chapter 3, page 16, "Elevated Temperature, Unknown Vapor Pressure", OCA Guidance) -released into building, 5% of outside release (Chapter 7, pages 12 & 13, OCA Guidance) -wind speed (3.0m/sec) and atmospheric conditions [("D" Stability) (C hapter 1, page 3; OCA Guidance)] -calculations and distances (Chapters 4, 5, OCA Guidance) -buoyant gas due to increased temperature (90 degrees centigrade) -urban topography (40 CFR 68.2 (e)) -appropriate tables (Chapter 10, OCA Guidance) -residential receptors estimated using actual residence counts times estimated person per household, southern region - (ST-96-20R "Estimates of Housing Units, Households, Households by Age of Household and Persons per Household", Population Estimates Program, Population Division, US Bureau of the Census as of 7-1-96, Internet date 7-7-97, revised 8-21-97.) d) The SEACO accidental release prevention program, which covers the handling, storing and processing of raw materials and products stored on site, is included in the SEACO Programs and Policies Manual. This program is designed to be proactive and is therefore, constantly evolving with improvements to our safety program being a top priority. At present, SEACO als o maintains specific prevention steps for many of the chemicals present at our facility. Chem-specific guidelines address proper training, handling and storage methods prescribed by OSHA, EPA, and other industry specific agencies. Inspections and monitoring of all formaldehyde transfer and delivery into storage and process reaction vessels, weight differential transfer systems for raw material delivery to reaction vessel, manual shut-offs of piping delivery, etc., equipment inspection, maintenance and daily visual inspections of on-site storage, processes, equipment and overall conditions helps to ensure the early detection of any accidental release at this SEACO facility. e) A review of accidental releases over the past five (5) years reveals that SEACO- Lenoir, NC has had no accidental releases resulting in deaths, injuries and damage to on- site, off-site, public or environmental receptors (40 CFR 68.42). However, in late August of 1997 a complaint of an unpleasant odor origina ting at our facility was filed. Investigation by on-site personnel, commercial tank emissions testing and estimates, and state investigation by NCDEHNR personnel revealed no leak or spill and total compliance with all standards and regulations for emissions, etc.. It was determined that the "odor" was produced during a storage tank cleaning procedure. SEACO conducted a review of these procedures and adopted improved cleaning methods to reduce emissions during tank cleaning. No evacuation / emergency procedures were instituted as a result of this incident. f) In detail, SEACO's "Emergency Response Program" contains pertinent information dealing with the procedures to follow if an emergency situation should present itself. The program covers in-house emergency response procedures and designated responders and their duties, emergency action procedures, pertinent phone numbers of responsible company personnel and community emergency responders, next of kin notification information, a fire prevention program with locations of all extinguishers, site map with designated evacuation routes and exits, personnel and medical information and procedures. In case of emergency the following personnel should be contacted: Don Barrier, President (828) 754-3493 or (828)754-8371 (emergency, after hours) Tony Cohee, Plant Manager (828) 754-3493 or (828)728-0047 (emergency, after hours) Nancy Feimster, Safety & Environment (828) 754-3493 or (828)757-9387 (emergency, after hours) g) The safety of our personnel and facilities, our surrounding neighbors, and our environment is a top priority for SEACO. We are constantly monitoring our situations for potential problems and seeking solutions. Our "Safety Committee" conducts monthly inspections and is refining our procedures for dealing with accidental releases and employee training. |