The Genesee Brewing Company - Executive Summary |
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The Genesee Brewing Company (GBCo) produces beer and ale products. GBCo uses anhydrous ammonia in its refrigeration system to provide space cooling, and to chill water, beer, and glycol. The amount of ammonia in the entire refrigeration system is estimated to be 80,000 lbs. Because GBCo stores more than 10,000 lbs of ammonia in its refrigeration system, it is covered by the EPA regulation 40 CFR Part 68 - Accidental Release Prevention Requirements: Risk Management Programs, and the OSHA regulation 29 CFR 1910.119 - Process Safety Management of Highly Hazardous Chemicals. The EPA program will be hereafter identified as RMP, and the OSHA program will hereafter be identified as PSM. The RMP focuses more on impacts to the environment and public receptors, while the PSM program focuses more on worker safety. However, the primary goal of both programs is to prevent or minimizing the consequences of catastrophic releases of hazardous chemicals. GBCo is already in compliance with the PS M program, which requires action items like mechanical integrity inspections, preventative maintenance, and employee training - all of which help to prevent accidental ammonia releases. Many requirements in the PSM program are identical to those listed in the RMP program. GBCo is committed to safety, and is a responsible member of the Rochester community. In addition to complying with the PSM and RMP regulations, GBCo also has a facility Emergency Action Plan, and Contingency Plans for responding to releases of other chemicals, petroleum, and hazardous wastes. We have a full time Security Department which is trained to respond to emergencies, and we also have an on-site Emergency Action Team. GBCo has established good working relationships with local emergency response authorities and the Local Emergency Planning Committee. If a significant off-site release of anhydrous ammonia were to occur, GBCo believes it is well prepared to quickly, safely and effectively respond to the inc ident, and to interface and coordinate response activities with local emergency officials. Although minor ammonia leaks and releases do occasionally occur in any large and complex refrigeration system, GBCo has never experienced an anhydrous ammonia release which adversely impacted off-site public and environmental receptors such as commercial and private businesses, industries, schools, public buildings, national or state parks, wild life sanctuaries, or designated federal wilderness areas. The RMP regulation requires a facility owner to determine a "worst-case release scenario". Using the instructions provided in the regulation, a GBCo worst case release scenario would be the release of approximately 10,000 lbs of anhydrous ammonia, which within 10 minutes could cause a gaseous ammonia concentration of 200 ppm at a distance of 1.7 miles from the facility. Although this worst-case scenario is possible, it is extremely unlikely to occur. The RMP regulation also requires a facility owner to determine an "alternative release scenario analysis" which would be more likely to occur than the worst case release scenario. Using the instructions provided in the regulation, a GBCo alternative release scenario would be the release of approximately 194 lbs of anhydrous ammonia, which could cause a gaseous ammonia concentration of 200 ppm at a distance of 100 feet from the source of the leak. It is extremely unlikely that this type of release would have any off-site impact whatsoever. The ammonia concentration of 200 ppm is the "toxic endpoint" as defined in the RMP regulation. The toxic endpoint values were adopted by the EPA from the American Industrial Hygiene Association Emergency Response Planning Guideline Level 2 (ERPG-2). The ERPG-2 is defined as the concentration of the toxic chemical at which almost all people could be exposed for one hour without irreversible or other serious health effects or symptoms that would impair their ability to take protective actio ns. |