Coors Brewery, Golden - Executive Summary
The Coors Brewing Company (CBC) operates brewing and can manufacturing facilities in Golden, Colorado. These facilities use 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. The regulated toxic chemicals at these stationary sources are ammonia and chlorine. |
This document addresses the five EPA regulatory requirements for a RM Plan which form the basis of the RM program for the Golden facilities. EPA's five key regulatory requirements for a 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 t
he requirements listed above and is organized to reflect 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 Environment, 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. Utility 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, including management, hazard assessment, prevention, emergency plann
ing, and RM plan updates.
Requirement 2. Hazard Assessment
Potential accidental releases of ammonia and chlorine were modeled to evaluate possible 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). The offsite population estimates do not include 3,750 CBC employees at Golden. RM Regu
lations 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 reporting to the EPA.
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 27,070 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.
e of 20,700 pounds of ammonia 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 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 7,800 is located within this radius. For ammonia, the ACS selected has an endpoint distance of 0.7 miles. An estimated population of 7,500 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 requiri
ng 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. Key provisions of the release prevention program are as follows.
For the ammonia and chlorination processes (which are subject to the PSM standard), EPA requires a Program 3 prev
ention program with 12 specific elements as listed below and described in Section 3.0:
- 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 Golden is based on training all personnel to recognize releases and immediately inform Security by telephone at extension 73333. 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 familiar with the affected process. The AHJ will initially b
e the City of Golden Fire Department. The AHJ can call additional external emergency response resources to the scene including the Jefferson County Sheriff, Colorado State Patrol, 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 Section 5.0. The data elements are supported by this RM plan which documents and provides additional details for each RM regulatory requirement. Section 5 consists of a complete printout from EPA's RMP Submit software.
The Utilities department is in the process of automating existing valves that separate the system into zones. This modification will enable the isolation of a zone if a serious leak had occurred 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.