Miller Brewing Company (Fort Worth, TX) - Executive Summary |
|
EXECUTIVE SUMMARY The Miller Brewing Company is committed to promoting a safe working environment and has developed and implemented several programs to ensure chemical safety. The facility operates an ammonia refrigeration process and has several methods for ensuring employee and public safety associated with this process. The facility has developed procedures, plans and policies for the operation of the ammonia process and for dealing with unexpected accidental releases. The Miller Brewing Company has implemented a process safety management program which enhances safety by regular maintenance and inspections, hazard analysis, compliance audits, employee and contractor training, employee participation, ammonia monitoring/detection, and other activities. The Miller facility has an Emergency Response Team and a Utilities Response Team complete with state-of-the-art emergency response equipment. Both teams are trained to quickly and effectively respond to a release of hazardous mater ials. The facility also has emergency response procedures and plans to promote chemical safety in the event of an emergency situation. The Miller Brewing Company is engaged in the beer production business. As part of the brewing process, an ammonia refrigeration system is utilized. Due to the quantity of ammonia maintained on-site, the facility is subject to the Risk Management Program regulations which are meant to promote safety at the facility and general public level. A worst-case release scenario was modeled to determine the greatest impact a release of ammonia from the facility could reasonably cause. This scenario is based on a complete and total release of ammonia from the largest ammonia vessel located at the facility. At the Miller facility, this scenario involves a vessel which has an administratively controlled capacity of 9,075 pounds of ammonia (company policy limits the filling of the vessel to 80% of its total capacity). The worst-case release of ammonia from t his vessel is a complete loss of all 9,075 pounds of ammonia in a ten minute period. Computer modeling was used to reasonably evaluate the impacts from such a release. The modeling indicates that impacts from the worst case release would impact public receptors beyond the property boundaries. Although the vessel is located within a building, it was assumed that the building would not mitigate the release due to wall openings and the light metal construction of many of the walls. However, the building would tend to mitigate smaller releases. An alternative release scenario was also modeled using the EPA lookup tables. The alternative release scenario is based on a small leak or hole (i.e. < inch) in one of the ammonia vessels or pipelines at the facility. The alternative release scenario is a scenario which is more likely to occur than the worst-case scenario. Based on the modeling, it was determined that such a leak could result in impacts to the public receptors beyond the prope rty boundaries. In the previous five years, the Miller facility has not had any accidental releases which resulted in any deaths, injuries, or significant property damage on-site, or known off-site deaths, injuries, evacuations, sheltering-in-place, property damage, or environmental damage from the ammonia process. The Miller facility is also subject to the Process Safety Management regulations under the Occupational Safety and Health Administration (OSHA). As a result of these regulations, the Miller facility has implemented a program to further enhance process safety which involves operating procedures, training, mechanical integrity (maintenance related issues), pre-start-up-review, management of change, compliance audits, incident investigation, employee participation, hot work (welding) permits, and contractor safety. The facility's emergency response program consists of three major plans/procedures: an Emergency Action Plan, an Emergency Contingency Plan and a Standard Operat ing Procedures for Emergency Responders (SOPER) that is part of the Process Safety management Program. The emergency response plans/procedures at the Miller facility contain information and procedures relative to initial response, informing the public, evacuation, fire response, facility specific information (site maps/drawings, security, communication system, emergency organization), emergency/spill prevention, post emergency procedures, training summary, and administrative management of change. Additional information on initial response is included in the Ammonia Refrigeration System Emergency Isolation Valve Maps. As previously mentioned, the brewery maintains both an Emergency Response Team and a Utilities Response Team. Both teams receive extensive annual training to deal with an accidental release at the facility. Equipment used by the teams is routinely tested and maintained. The emergency response plan for the facility has been submitted to and approved by the Tarrant County Local Emergency Planning Committee (LEPC). Annually, the Fort Worth Fire Department conducts a Fire Safety inspection of the brewery and participates in a brewery tour. |