Bush Boake Allen Inc., Jacksonville - Executive Summary

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The Jacksonville facility of Bush Boake Allen Inc. (BBA) is committed to providing each employee and the citizens of the surrounding community with a safe working and living environment. It is BBA's policy to conduct chemical manufacturing operations in a safe and environmentally sound manner. BBA has the expertise, experience and training to handle the materials used at the Jacksonville facility in a safe and environmentally sound manner. In the event of an incident at the facility or involving our materials, BBA is committed and prepared to properly respond so that life and property are protected to the greatest extent possible. 
BBA processes turpentine at the Jacksonville facility and converts it to various terpene and synthetic aroma chemicals. Several hazardous substances are used in BBA's processes, but BBA has only one substance in a "covered process"  subject to the US Environmental Protection Agency's  Accidental Release Rule(under Program 3), due to its potential for off-sit 
e consequences in the unlikely event of a major release. This substance is Anhydrous Hydrogen Chloride (AHCL), which is delivered to the facility by rail in 70-ton tank cars and used directly from the tank cars. AHCL is a common industrial chemical that has been safely used for many decades. It is stored as a liquid under pressure in the rail car, transferred to a vaporizer and piped directly to the process where it is used as a reactant. Only the tank car holds a sufficient quantity of AHCL to pose a risk for off-site consequences in the event of a release. If released, the AHCL will immediately vaporize and form a dense, visible white cloud that is carried by the wind as it dissipates. 
AHCL vapor is highly irritating to breathe and moderately toxic. A sufficiently high dose can be fatal. In the event of a release, concentrated vapor can be recognized by its dense, white plume. Its sharp, pungent odor can be detected in very low concentrations. Anyone exposed to a release should avoi 
d the vapor plume if possible or take shelter inside a building until the plume passes, which would be a matter of minutes under typical weather conditions. Sheltering-in-place involves entering an enclosed building, immediately closing windows and doors, turning off all ventilating or air conditioning systems, turning on the radio or TV for emergency bulletins and staying calm until it is announced that the emergency is over. 
EPA's Accidental Release Rule requires the description and analysis of a worst-case release scenario. Recognizing the extreme unlikelihood of a worst-case release, the EPA also requires at least one alternative, or "more likely" scenario to be described and analyzed. The probability of an alternative release scenario occurring at BBA's facility is also very low. 
EPA requires BBA's worst-case scenario to be described as a near-instantaneous release of an entire rail car full of AHCL under worst-case weather conditions, where the vapor plume would dissipate the l 
east and extend the farthest. Although extremely unlikely to occur, such a release under these worst-case conditions could result in a vapor plume traveling a long distance before dissipating to safe concentrations. Numerous similar scenarios exist throughout the nation and in every large city. Rail tank cars are extremely durable, being designed to safely transport dangerous chemicals in everyday commerce and to withstand railroad crashes. At BBA, the rail cars are securely parked inside the facility at the end of a rail siding and are not exposed to any traffic or other hazardous conditions while in use. 
BBA's analysis considered possible release scenarios described by the Chlorine Institute in its off-site consequences analysis document, Pamphlet 160. The Chlorine Institute is a long-established and authoritative industry association of producers and users of chlorine, anhydrous hydrogen chloride (AHCL) and hydrochloric acid. Chlorine and AHCL have similar properties and are handle 
d and transported in nearly identical manners, although AHCL is less toxic and not as widely used as chlorine. Among the possible alternative release scenarios described in Pamphlet 160, several were recognized to be generally applicable to BBA's covered process. The scenario chosen as BBA's alternative release scenario was slightly modified to match  the specific features of BBA's transfer system and typical Jacksonville weather data. It is expected that BBA's release scenarios will be very similar to those described by many other facilities handling similar chemicals with similar transfer systems.  
BBA's alternative release scenario is described as a partial rupture of a transfer hose used to convey liquid AHCL from the rail car to the facility piping. A large or complete rupture of the hose would activate the "excess-flow" valve  inside the rail car, causing it to instantaneously close when the flow exceeds 250 lb. per minute. Therefore, this scenario describes a partial rupture  w 
here the flow would approach, but not exceed, 250 lb./min. and not automatically close the excess-flow valve. (In Section 3.6 of this document, the release rate is entered as 300 lb./min. due to required rounding of the number.) As soon as such a release is detected it would be immediately terminated by closing a remote-activated shutoff valve upstream of the hose. The duration of the release would be the elapsed time to detect and terminate it, conservatively estimated to be five minutes. Such a release, although unlikely, could result in the surrounding neighborhood being exposed to unsafe concentrations of AHCL vapors for several minutes. The affected distance and duration would depend on the exact rate and duration of the release and the prevailing weather conditions. This is one of several possible alternative scenarios that were identified and analyzed, but it is considered possibly more likely to occur and would result in greater exposure than the other scenarios. The rupture of 
a vapor transfer hose or a stuck-open rail car relief valve could have similar, but probably somewhat less severe consequences. 
The Chlorine Institute's release scenarios were modeled by SAFER Systems, L.L.C., using its proprietary TRACE dense gas model. BBA's scenarios were modeled by the same firm, using the same model, based on the work done for the Institute. 
The Chlorine Institute describes and promotes the use of systems and equipment for the safe transport and handling of these chemicals. BBA's AHCL unloading and transfer system was redesigned, upgraded and rebuilt in 1996 and now substantially incorporates the state-of-the-art safety features described in the Chlorine Institute's Pamphlet 57. Safety features include strategically placed release detection sensors, closed circuit color television monitoring and fail-safe remote-actuated shutoff valves, including remote-actuated shutoff valves close-coupled to the rail cars upstream of the transfer hoses. Burst diaphragms p 
rotecting the transfer system from over pressurization are vented to a wet scrubber to prevent the release of AHCL. Operating, maintenance, and supervisory personnel trained to operate the system and to respond to any emergency situation are on duty 24 hours a day, every day of the year. The transfer system is designed, operated and maintained in accordance with OSHA's Process Safety Management Standard, as detailed in Section 7 of this document. BBA's facility is also certified and operated in accordance with ISO 9000. 
There have been no reportable accidents involving AHCL in more than five years. 
BBA has always recognized its responsibility to manage AHCL safely and to be able to respond to an accidental release. A formal Emergency Response Plan has been in place for more than two decades and is kept up to date. Facility personnel are trained in their appropriate level of emergency response and retrained annually, in accordance with formal procedures and OSHA's "HAZWOPER" rule (29  
CFR 1910.120). Drills are conducted quarterly and occasionally involve the participation of the city's Hazardous Materials Response Team. Jacksonville's Emergency Preparedness Division, Fire and Rescue Department, would be notified immediately in the event of a major release and would be responsible for conducting off-site response activities. 
Incidents and near misses are required to be thoroughly investigated to learn what can be done to further improve the safety of BBA's systems and procedures. BBA is always actively seeking to improve safety and reduce risk to its employees and the surrounding community.
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