Southeastern Adhesives Company - Executive Summary

| Accident History | Chemicals | Emergency Response | Registration | Source | 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 
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 
   -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 
   -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 
      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 
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  
   -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 on- or off-site deaths or injuries, or 
damage to off-site, public or environmental receptors (40 CFR 68.42). However, on 
August 3, 2000 SEACO experienced an accidental release 
of approximately 10,000# of 
formaldehyde in a 1% methanol, 49% water solution. The liquid/vapor release remained 
on-site and the only damage was due to mitigation. All appropriate federal, state, and 
local agencies were notified. At present, SEACO is in correspondence with NCDENR in 
Ashville through our insurance representative ECS Risk Control regarding mitigation and 
closure of the release area. The only other incident worth noting occurred in late August 
of 1997 when a complaint of an unpleasant odor originating 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 defines specific emergency situations and states in-house emergency 
response procedures, 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) 
Richard "Buddy" Anderson, Director of Operations: 
               (828) 754-3493 or (828)758-7581 (emergency, after hours) 
Tony Cohee, Plant Manager:    (828) 754-3493 or (828)728-0047  
(emergency, after hours) 
Nancy Feimster, Safety & Environmental Compliance: 
               (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.
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