Coors Brewing Company, Memphis - Executive Summary
The Coors Brewing Company (CBC) operates a brewing, blending, finishing, and packaging facility in |
Memphis, Tennessee (Memphis facility). The facility uses ammonia in the refrigeration system. Use of
ammonia is regulated under the Clean Air Act Amendments (CAAA), Section 112(r), and the United States
Environmental Protection Agency (EPA) Accidental Release Prevention Risk Management (RM) Planning
regulations (40 CFR, Part 68) herein referred to as the RM regulations. Under the CAAA and the RM
regulations, the facility is considered to be a stationary source.
Five EPA regulatory requirements for a RM Plan form the basis of the RM program for the Memphis facility. EPAs five key regulatory requirements for an RM program are:
1) Management Plan
2) Hazard Assessment
3) Accidental Release Prevention Program
4) Emergency Response
5) Risk Management (RM) Plan and Data Elements
Requirement 1. Management Plan
The RM Program Manager for CBC is a Senior Environmental, Health & Safety
(EHS) Manager who reports to the Director, Core Environmental, Health, Safety, and Energy (EHSE), who, in turn, reports to the Vice President, Engineering and Technical Services. The RM Program Manager is assisted by a Process Safety Management (PSM) Coordinator and an EHS representative. The PSM Coordinator is responsible for the accidental release prevention program for the ammonia refrigeration process. Utilities supervisors,
maintenance supervisors, operators, engineers, and staff level personnel also execute component activities to maintain compliance with RM regulations. At Memphis, individuals have been assigned responsibility for all five requirements of the RM program.
Reguirement 2. Hazard Assessment
Potential accidental releases of ammonia were modeled to evaluate possible offsite impacts. Modeling
procedures followed EPA guidance to identify worst case release scenarios (WCS) and altern
release scenarios (ACS) as defined by the RM regulations. EPA personnel freely admit that the assumptions used for WCS are not realistic and in some cases are not physically possible. However, EPA
guidance was followed and an endpoint was identified. The WCSs were identified by comparing the results for the ammonia system and selecting the scenario that resulted in the greatest distance to the endpoint. The number of offsite permanent residents located inside a circle (centered on the release point with a radius equal to the endpoint) was then estimated using EPAs Landview III software (Version 1.0). This software is the approved EPA source, but inconsistencies due to approximations necessary in considering small land areas. The offsite population estimates do not include 521 CBC employees at Memphis. RM Regulations require reporting of a WCS and ACS for the regulated process.
A release of 17,000 pounds of ammonia in 10 minutes was identified as the WCS for the
refrigeration process. This WCS would produce an endpoint (defined as 200 parts per million [ppm]
ammonia) of 2.4 miles. An estimated offsite population of 35,000 is located within this radius.
To develop more realistic estimates of offsite impacts, as required by RM regulations, several ACSs were
evaluated for the ammonia refrigeration system. The ACS selected was based on industry recommendations and likelihood of occurrence, and is still considered conservative. The ACS consists of a >-inch Schedule 80 pipe failure, which contains liquid ammonia under pressure. This results in an endpoint distance of 0.65 miles. An estimated offsite population of 260 is located within this radius.
In the past five years, the process subject to RM regulations has had no releases that have resulted in offsite property damage or offsite health consequences requiring medical treatment for chemical releases or fire. ). The facility has had other releases that are reported to EPA unde
r the Emergency Planning and Community Right-to-Know Act (EPCRA/CERCLA).
Requirement 3. Prevention Program
The Memphis facility has a chemical release prevention program for ammonia. The prevention program
was developed to comply with Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations (29CFR 1910.119). For the process (which is subject to the PSM standard), EPA requires a Program 3 prevention program with 12 specific elements as listed below:
- Employee Participation
- Process Safety Information
- Process Hazard Analysis
- Operating Procedures
- Pre-Startup Safety Review
- Mechanical Integrity
- Hot Work Permit
- Management of Change
- Incident Investigation
- Compliance Audits
Requirement 4. Emergency Response
The emergency response program at the facility is initiated by CBC personnel who are all trained to
recognize ammonia releases and immediately notify the Safety Department. Ammonia gas sensors/a
are present at five locations that automatically trigger audible alarms and alert the Safety Department if
ammonia is detected. Employees contact the Safety Department using radios that are monitored 24 hours per day. CBC personnel not carrying radios who notice a release are to clear the area immediately and notify their supervisor, or others who carry radios so they can inform the Safety Department.
The Safety Department has Incident Command Level trained individuals (at least one is onsite) who
are sent to the scene to assess the situation and engage the proper internal and external emergency response personnel and equipment. When external emergency responders arrive, a joint command is then
established which is led by the authority having jurisdiction (AHJ), and supported by the Safety
Department, and CBC personnel. The AHJ will initially be the City of Memphis Fire Department. The AHJ can call additional external emergency response resources to the scene that incl
ude the Shelby County Hazardous Materials Team, Shelby County Sheriff, Tennessee State Patrol, and other agencies, as needed. These external agencies are responsible for evacuation of nearby businesses should the situation require it.
Requirement 5. RM Plan and Data Elements
The specific data elements required to be electronically reported to EPA are included in this submittal. The
data elements are supported by an RM plan which documents and provides additional details for each RM