Miller Brewing Company (Trenton, OH) - Executive Summary |
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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 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 proces s, 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 17,600 pounds of ammonia (company policy limits the filling of the vessel to approximately 60% of its total capacity). The worst-case release of ammonia from this vessel is a complete loss of all 17,600 pounds of ammonia in a ten minute period. Computer modeling was used to reasonsably evaluate the impacts from such a release. The modeling indicates that the worst case release wo uld impact public receptors beyond the property boundary. The release would be mitigated by the building structure. An alternative release scenario was also modeled using the EPA lookup tables. The alternative release scenario is based on the failure of a six inch valve in the utiliities building which would result in an ammonia release of 380 pounds per minute. 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 public receptors beyond the property boundaries. This release would also be mitigated by the building structure. 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 emergency response plan at the Miller facility contains information and procedures relative to evacuation, fire response, chemical releases, severe weather, and facility specific information (site maps/drawings, and evacuation routes). The St. Clair Township Fire Department and the regional HAZMAT teams visit the site on a regular basis. |