Southeastern Adhesives Company- Ridgeway, VA - 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 on-site and offsite private, public and environmental receptors. The scenarios prescribed for investigation include both a worst-case and an alternative release which could possibly 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 storage of all process chemicals and products, as well as, chemicals used in the day to day operations of our facility and it 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 the appropriate actions which are spelled out in the emergency plan, thus ensuring the safety of its employees, surrounding neighbors, and environment. SEACO's emergency response plan has been coordinated with the Henry County Local Emergency Planning Committee and should provide the necessary factors, such as communication, spill response and clean up, etc., to facilitate proper and safe response to any emergency situation which should arise at the SEACO stationary source. Both SEACO's "Accidental Release Plan" and "Emergency Response Plan" are contained in its general Programs and Policies Manual. b) SEACO owns and op erates 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 PO Box 527 Ridgeway, VA 24148 This RMP*Submit plan covers SEACO in Ridgeway, VA only. The SEACO facility in Ridgeway, VA manufactures 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 a 10,000 gallon reactor. 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 applicable 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 103,000. pounds. at the Ridgeway, VA plant (stationary source). The formaldehyde is stored as a liquid in a 50% formaldehyde, 1% methanol, 49% water solution at 55 - 60 degrees centigrade and is contained in two12,000 gallon stainless steel storage tanks which are held to a maximum of 11,000 gallons each by Adminis trative controls to prevent overfilling. These tanks are surrounded by a dike / sump passive mitigation system. c) The worst-case release scenario would be triggered by rupture of a main storage tank, potentially resulting in a spill of 52,000. pounds or 11,000 gallons 50% formaldehyde solution at 55 - 60 degrees centigrade into ambient surroundings. In the event of such a large scale spill, there is a passive mitigation diking system consisting of a large dike and sump area. The diked area alone has a capacity of over 13,000 gallons and is therefore large enough 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 mig ht warrant evacuation of the stationary source and notification of appropriate emergency response agencies who are designated to respond to any potential crisis situation. The following worst case scenario parameters were used in determining the data included in this RMP: -52,000lbs. formaldehyde released [50% by weight concentration in water, 11,000 gallons @ 50 - 65 degrees centigrade. When released into ambient conditions, formaldehyde under goes non-hazardous polymerization (hardens) to form paraformaldehyde at less than 50 degrees centigrade, thus reducing its evaporation rate] -released at once, on ground level ( 40 CFR 68.22(d), Exhibit 1 and Chapter 3; OCA Guidance) -release rate over 10 minutes for water solution ( Chapter 3, page 15,16,17; OCA Guidance) -passive mitigation, dikes and sumps limiting pool surface area and Administrative controls limiting the storage of the formaldehyde tanks to 11,000 gallons each -wind speed (1.5 m/s)and atmospheric conditions [( "F" stability), ( Chapter 1, page 3; OCA Guidance)] -urban topography (40 CFR 68.22(e)) -formulas as per Chapter 3 and Appendix D; OCA Guidance, as formaldehyde concentration was not listed in table -temperature, liquid density and vapor pressure values obtained from supplier. -appropriate tables (as per Chapter 4 & 5; 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.) 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 sce nario 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 reactor. 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, ve ssel size and experience, a quantity of half (50% x 60,000lbs) 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 scenario parameters were used in determining the data included in this RMP: -half the quantity (0.5 x 60,000lbs.) of 50% formaldehyde solution [(50% formaldehyde, 1% methanol, 49% water) at 55-60C] charged to 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, pag es 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/s) and atmospheric conditions [("D" stability), (Chapter 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 pro-active and is therefore, constantly evolving with improvements to our safety program being a top priority. At present, SEACO also maintains specific prevention steps for many of the chemicals present at our facility. Chem-specific guidelines address proper training, handling and storage, clean-up and disposal methods prescribed by OSHA, EPA, and other industry specific agencies. Inspections and monitoring of all the 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 one potentially significant leak of formaldehyde. During a daily visual inspection by the facilities manager it was noted that a large quantity of 50% formaldehyde in water had leaked into the diked area surrounding the storage tank. This solution was pumped into a tanker truck as was the remaining formaldehyde solution in the storage tank. Investigation revealed that the old storage tank was made from inappropriate material and years of corrosion had produced a hole in the tank. This storage tank was replaced on 04/17/99 with a stainless steel tank that meets the requirements for formaldehyde storage. No complaints were received as a result of this incident. As per (40CFR 68.42) no known on-site deaths, injuries, or significant property damage or known offsite deaths, injuries, evacuations, sheltering in place, property damage, or environmental damage occurred as a result of this incident; therefore, it does not constitute an "accidental release". 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: Doug Stewart, Plant Manager (540) 956-3176 or (540)629-1449 (emergency, after hours) Don Barrier, President (828) 754-3493 or (828)754-8371 (emergency, after hours) Elwood Duncan, Assistant Plant Manager (540) 956-3176 or (540)956-5319 (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 at present we are concerned with increasing the size of our passive mitigation diked area (by adding a foot in height to the total perimeter of the dike) so it, in conjunction with the attached sump area will contain the total contents of both formaldehyde storage tanks. SEACO is also making improvements to drainage and run- off of areas with increased potential for accidental spills and releases. |