Coors Brewing Company, Memphis - Executive Summary |
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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. The regulated toxic chemical at the stationary source is ammonia. This document addresses the five EPA regulatory requirements for a RM Plan which form the basis of the RM program for the Memphis facility. 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 an d Data Elements This RM plan is based on the 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 process. Utility 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, including management, hazard assessment, prevention, eme rgency planning, and RM plan updates. 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 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 and flammable 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 or flammable 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 502 CB C employees at Memphis. RM Regulations require reporting of a WCS and ACS for each regulated process that could impact different offsite populations. A release of 17,500 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 2.4 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 for presentation in this document and for reporting to EPA was selected based on industry recommendations and likelihood of occurrence. The selected 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. I n 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 requiring medical treatment for chemical releases or fire. Requirement 3. Prevention Program The Memphis facility has a chemical release prevention program for ammonia. The prevention programs for the ammonia process were developed to comply with Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) regulations (29CFR 1910.119). Key provisions of the release prevention program are as follows. For the ammonia refrigeration process (which is subject to the PSM standard), EPA requires a Program 3 prevention program with 12 specific elements as listed below and described in Section 3.0: - Employee Participation - Process Safety Information - Process Hazard Analysis - Operating Procedures - Contractors - Pre-Startup Safety Review - Training - Mechanical Integrity - Hot Work Permit - Man agement 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 inform the Safety Department. Ammonia gas sensors/alarms 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 radio contact since channel #1 is maintained for this purpose 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 nine (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 exter nal 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 who know the affected process well. The AHJ will initially be the City of Memphis Fire Department. The AHJ can call additional external emergency response resources to the scene that include 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 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. |