Coors Brewery, Golden - Executive Summary
The Coors Brewing Company (CBC) operates brewing facilities in Golden, Colorado. CBC participates in a joint venture which manufactures cans on the same property. CBC uses chlorine and ammonia. Use of these chemicals 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, these facilities are considered to be stationary sources. |
Five EPA regulatory requirements for a RM Plan form the basis of the RM program for the Golden facilities. EPA's 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
This RM plan is based on the requirements listed above and is organized to refle
ct them in five sections, as summarized below.
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, ammonia nutrient, and chlorination processes. Utilities supervisors, maintenance supervisors, operators, engineers, and staff level personnel also execute component activities to maintain compliance with RM regulations. At Golden, individuals have been assigned responsibility for all five requirements of the RM program.
Requirement 2. Hazard Assessment
Potential accidental releases of ammonia and chlorine were modeled to evaluate poss
ible offsite impacts. Modeling procedures followed EPA guidance to identify worst case release scenarios (WCS) and alternate case 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 toxic endpoints were identified. The WCSs were identified by comparing the results for each ammonia or chlorine system and selecting the scenario that resulted in the greatest distance to the toxic 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 EPA's Landview III software (Version 1.0). This software is the approved EPA source, but inconsistencies due to approximations necessary isn considering small land areas. The offsite population estimates do not include 3588 CBC employees at Golden. RM Regulations require
reporting of a WCS and ACS for each regulated process that could impact different offsite populations. During the hazard assessment of the Golden facility it was found that the WCSs for all regulated processes would affect somewhat different populations. Therefore, WCSs for all three regulated processes have been selected for submission.
A release of 2,000 pounds of chlorine in 10 minutes was identified as the WCS for the chlorination of domestic water process. This WCS would produce a toxic endpoint (defined as 3 parts per million [ppm] chlorine) of 3.0 miles. An estimated offsite population of 9,200 is located within this radius.
A release of 27,000 pounds of ammonia in 10 minutes was identified as the WCS for the ammonia nutrient addition to process wastewater process. This WCS would produce a toxic endpoint (defined as 200 parts per million [ppm] ammonia) of 3.0 miles. An estimated offsite population of 7,200 is located within this radius.
A release of 21,000 pounds of ammo
nia in 10 minutes was identified as the WCS for the ammonia refrigeration process. This WCS would produce a toxic endpoint (defined as 200 parts per million [ppm] ammonia) of 2.6 miles. An estimated offsite population of 3,500 is located within this radius.
To develop more realistic (although still conservative) estimates of offsite impacts, as required by RM regulations, several ACSs were also evaluated for the ammonia and chlorine systems. For the toxics, one chlorine and one ammonia ACS were identified for emergency response planning purposes. The alternate chlorine release has an endpoint distance of 1.1 miles. An estimated population of 1500 is located within this radius. For ammonia, the ACS selected has an endpoint distance of 0.65 miles. An estimated population of 900 is located within this radius.
In the past five years, none of the processes subject to RM regulations have had releases that have resulted in offsite property damage or offsite health consequences requi
ring medical treatment for chemical releases or fire. One release of ammonia vapor occurred on August 28, 1997. However, offsite consequences were avoided by timely detection by employees and a rapid response by Coors, the Golden Fire Department, and the Colorado State Patrol (closure of Highway 58). Other chemical releases have occurred at the facility that have not had offsite impacts. These releases have been reported to the EPA as required.
Requirement 3. Prevention Program
The Golden facility has a chemical release prevention program for each regulated process. The prevention programs for the chlorine and ammonia processes were developed to comply with Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations (29CFR 1910.119) and have been in place since 1993. The 12 key provisions of the release prevention program for the ammonia and chlorination processes, for which EPA requires Program 3 prevention programs, are as follows. :
- 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 Golden is based on training all personnel to recognize releases and immediately notify Coors Security by telephone. Security sends a trained officer to the scene to assess the situation, act as the initial Incident Commander, and engage the proper internal and external emergency response personnel and equipment. When external emergency responders are needed, a joint command is then established which is led by the authority having jurisdiction (AHJ) and supported by CBC Security and CBC personnel. The AHJ will initially be the City of Golden Fire Department. The AHJ can call additional external emergency response resources to the scene including the Jeffe
rson County Sheriff, Colorado State Patrol, Jefferson/Adams County HAZMAT Team, and other agencies, as needed.
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 regulatory requirement.
The Utilities department is in the process of automating existing valves that separate the ammonia refrigeration system into zones. This modification will enable the isolation of a zone if a serious leak occurs to ensure that ammonia is not being supplied from other areas of the system. The valves will be operable from a central control room. Strobe lights at the valves will direct responding personnel to alternate control stations near each valve. The project will be completed by the end of 1999.