Pearl Brewing Company - Executive Summary

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                           Executive Summary 
  Pearl Brewing Company of San Antonio, Texas maintains a solid reputation within the 
community and throughout the region for high quality products and, above all, concern for 
employee and environmental safety.   Pearl Brewing Company implemented numerous safety 
and environmental initiatives in recent years.  Specific accomplishments are as follows; 
1.   Accidental Release Prevention and Emergency Response Policies - 
    Policy and prevention are spelled out in our Ammonia Refrigeration Process Safety 
Management (PSM) program, Spill Prevention, Control and Countermeasures Plan (SPCC), and 
the Storm Water Pollution Prevention Plan (SWPPP), Chemical Hygiene Plan, and the Safety 
and Health Program.   In addition to written guidelines for safe performance in the workplace 
and environmental awareness by all employees, safety and environmental consultants are 
routinely enlisted to conduct surveys, report findings and make recommendations to i 
facilility and employee safety.   Deficiencies are corrected by plant maintenance personnel, 
operators or assigned to a contractor for completion. A service agreement is in place with a local 
contractor (Eagle Construction and Environmental) to provide Hazmat assistance in the event of 
a major release.   Also, Pearl Brewing Company is represented at Bexar County Local 
Emergency Planning Commission (LEPC) monthly seminars.       
2.  Facility Information -  
    Pearl Brewing Company is located on thirteen acres north of the city center at the junction of 
Interstate 35 and U.S 281.   As a beer and beverage producer, ammonia mechanical refrigeration 
plays a key role in the process.  Anhydrous ammonia is the refrigerant of choice in large 
industrial applications.  Leaks are easily detectable, not damaging to the environment as it is 
produced by naturally occurring organic processes on a commercial basis, and replacement cost 
is low.   Our major effort lies in the safe and efficien 
t operation of the ammonia refrigeration 
system.  Our ammonia charge totals 36,000 lbs. to support a wide variety of refrigeration 
requirements in production, storage and product preparation for packaging.  Breweries use 
refrigeration for wort cooling, propylene glycol for attemperation, carbon dioxide liquifaction 
and maintaining low temperatures in the large storage cellars, yeast and hop storage rooms.   
Refrigeration is a process for removing heat from a space or substance, to bring about a 
reduction in temperature, by transferring that heat to another substance.   Cellars are normally 
held at low temperatures, typically 45-55 degrees F. for fermenting and 32-33 degrees F for 
storage and bottling and glycol temperatures range from 22-24 degrees F. 
3.   Worst Case Release Scenario and Alternative Release Scenario -     
Toxic Worst Case Scenario:   Environmental Protection Agency OCA guidance was used to 
develop a worst case release scenario for ammonia.   Ammonia Process Safety Ma 
(PSM) information contributed to the selection of the worst case scenario.   Normal operating 
level of our high pressure receivers is about 1300 lbs. as the refrigeration load varies slightly 
throughout the year.   Cellars are kept at constant temperatures within a few degrees and the only 
load variance comes from cooler and chiller start-up and shut-down for production.   The five 
separate ammonia receivers are the largest quantity of liquid ammonia under pressure (150 psi).   
A catastrophic release is unlikely, but could reach a .3 mile endpoint offsite.   The receivers are 
located in the engineroom mitigating a release to the environment.   Drains are situated to divert 
any unevaporated liquid to the sanitary sewer as opposed to a storm sewer outfall.   The sight 
glasses on the receivers could be vulnerable to accidental breakage only in rare circumstances.   
Each sight glass is protected by heavy metal guards to reduce the chance of damage from 
impact.   The receivers are  
not in a vehicular traffic area, but occaisionally fork lifts are used to 
move motors, pumps, etc. into and out of the engineroom.   A remote possibility of impact is 
present if a driver fails to use caution or if a mechanical failure of the lift occurs and the load 
shifts breaking a sight glass.   Only if immediate isolation near the point of impact is not 
possible could a catastrophic release take place. 
Toxic Alternate Case Scenario -   The alternate scenario would be an ammonia release from the 
Cascade ammonia receiver located outside the engineroom on the north side.  This receiver 
contains a large quantity (450 lbs.) of liquid ammonia under pressure (35 psi).   This vessel is 
located adjacent to other large tanks with a wooden overhead enclosure.   The other large tanks 
and the wooden overhead may not be able to withstand the effects of extreme weather or natural 
events, such as a tornado or flooding from torrential rain.   Recent severe flooding of the San 
Antonio River occurre 
d with several feet of water blanketing most of the plant grounds.   The 
water level rose and receded very quickly with tremendous force.   A variety of objects were 
observed being carried away during that period.   The water level rose to within a foot of the 
Cascade receiver.   Impact from displaced tanks, possible collapse of the wooden overhead 
enclosure, or collision from large floating objects could damage the vessel or more likely, the 
vessel's sight glass.   Again, any circumstances preventing immediate isolation at the point of 
release could result in a catastrophic release to the environment.   A catch basin has been 
constructed to direct unevaporated liquid from entering the storm sewer and diverting it to the 
sanitary sewer.   The vapor release has the potential to reach a .1 mile endpoint offsite.       
4.   General Accident Release Prevention Program and Chemical-specific 
Prevention Steps -  
     A major advance was made in developing and implementing the Ammonia Proce 
ss Safety 
Management (PSM) program.  This project was a mutual effort between plant personnel and a 
professional environmental consulting firm, Safe-T-Train, Inc. of San Antonio, Texas.   If a 
hazardous substance, in this case ammonia, is maintained on site in quantities of 10,000 lbs. or 
more, then 29 CFR 1910.119 requires a PSM program be in place.   As mentioned earlier, our 
charge as calculated by Mr. Thomas Collard, a Professional Engineer, is approximately 36,000 
lbs.   Upon completion of a thorough inspection lasting approximately 5 weeks of all ammonia 
equipment (compressors, evaporators, condensers, piping, valves, etc.), Mr. Collard noted in his 
final report, " All equipment is in a safe working condition, no unguarded dangerous machinery 
and the workplace at Pearl to be quite safe, generally.   It is my opinion that the equipment and 
piping are in safe working order, and that the refrigeration personnel do a remarkable job."    
     The Ammonia PSM program is implemented on 
a daily basis beginning with regular 
operator rounds.   The purpose of this program is not to merely meet an administrative 
requirement set forth by OSHA, but to ensure the safety of personnel, protect the environment 
and reduce release probabilities.   Ammonia leaks are corrected on the spot or internal work 
orders generated and in-house crafts or a qualified contractor selected to effect repairs.   
Equipment or system piping repairs require thorough evacuation prior to cutting or welding to 
prevent an explosion.   A lockout/tagout program ensures equipment may not be inadvertantly 
started or valves operated, which may cause injury/death or damage to equipment.   Key 
elements of the Ammonia Process Safety Management (PSM) program are: 
a.   Employee Participation:   Ammonia refrigeration system operators and maintenance 
personnel are aware of the hazards of ammonia and the danger it would pose to themselves, 
others and the environment should a major release occur.  OSHA mandates empl 
participate in development and implementation of the PSM program.  All employees have ready 
access to PSM files and documentation upon request.  Major areas included in the Employee 
Participation element are; 
-    Employee Awareness:   New employees are made aware of ammonia refrigeration PSM as 
part of their initial orientation.  The International Institute of Ammonia Refrigeration (IIAR) 
videos, "Ammonia, Refrigerant of the Future" are shown to help them gain an understanding of 
ammonia, why and how it is used in our refrigeration process, and the health hazards associated.   
In addition, recent Hazardous Waste Operations and Emergency Response Training (40-hour 
course) included an Ammonia PSM block of instruction to potential responders.  All recipients 
of this training acknowledge their awareness of Ammonia PSM by signing a document upon 
completion of the presentation.   
-    Employee Involvement:   At least one employee directly involved in the operation or 
maintenance of  
the ammonia system is present for meetings and/or discussions concerning 
ammonia refrigeration.  PSM procedures affecting hourly employees are discussed with at least 
one hourly in attendance at all times.   Any employee having concerns about aspects of the PSM 
program may direct his/her concerns to the Plant Engineer and Plant Safety Director.  Numerous 
plant ammonia safety procedures and policies are to be revisited at regular intervals, such as 
Process Safety Information accuracy and thoroughness, Operating Procedures validation, 
training, anticipated changes to the system, Emergency Planning and Response procedures, and 
once every three years an hourly employee will be involved in the PSM compliance audit.  All 
employees directly involved with the operation or maintenance of the ammonia refrigeration 
system may review the process safety information and process hazard analysis.  Such reviews are 
considered training and are conducted on company time. 
b.   Process Safety Informat 
ion:   Health and environmental hazards are listed in this element 
of which an MSDS (Material Safety Data Sheet) provides some of the necessary information.   A 
Process Technology section includes plant specific equipment operating safety parameters and 
devices, as well as Process Flow Diagrams and Piping and Instrumentation Diagrams.  A Block 
Flow Diagram or Process Flow Diagram shows the major components of the ammonia system 
and flow directions.  A Piping and Instrumentation Diagram depicts an in-depth view of all 
piping, valves, vessels, safety devices, etc. in a comprehensive set of engineering drawings.  
Approximately two years of intense effort by plant and contractor personnel were invested in 
this project. The Process Safety Information assesses all hazards of the ammonia system.  It is 
available to all employees and is included in the Ammonia PSM awareness lectures.  Process 
Safety Information is broken down into key catogories; 
Hazards of Ammonia: 
    - Chemical propertie 

    - Environmental effects 
    - Physical data 
    - Toxicity data 
    - Stability data (thermal and chemical) 
    - Reactivity data 
    - Corrosiveness 
    - Erosion effects  
    - Physiological effects and health information 
    - Fire protection information 
Process Technology Information: 
    - Simplified Block Flow or Process Flow Diagram 
    - Piping and Instrumentation Diagram 
    - Safe operating limits for; 
         --liquid levels 
    - Plant specific equipment information for; 
         --cascade ammonia system  
    - Process Risk Assessment and Severity     
    - Environmental Conditions in a Leak Area and Emergency Response 
c.   Process Hazard Analysis:   The purpose of this element is to identify possible conditions, 
practices, design problems, facility siting or human factors which could lead to a major relea 
A What-If-Checklist methodology was used employing approximately 260 potential release 
scenarios with consequences and associated assessments for each scenario.  A risk assessment 
matrix was employed to determine which scenarios held the greatest potential for a release. 
The Process Hazard Analysis (PHA) is a thorough and systematic method for identifying, 
evaluating, and controlling potential hazards within any process such as ammonia.  The scope of 
PHA was applied to all equipment and procedures involving the ammonia refrigeration system.  
The obvious objective was to identify possible deviations from process design, maintenance, 
inspection, or operating procedures which have the potential to cause a major release if no plant 
administrative or engineering controls are in place.   
Development of our PHA required a time-consuming and labor intensive process.  A key 
ingredient is selecting knowledgeable participants.  Personnel selected for the PHA Team had to 
be intimately famil 
iar with operational and maintenence aspects of the ammonia system.  The 
team members had to have the necessary experience to visualize the causes or deviations from 
normal operation of the ammonia system and evaluate current controls and their effectiveness.  
Next, the analysis had to be conducted using one of a variety of methodologies.  Methodologies 
available for consideration include; 
    - What-If 
    - Checklist 
    - What-If /Checklist 
    - Hazard & Operability Study (HAZOP) 
    - Failure Mode and Effects Analysis (FMEA) 
    - Fault Tree Analysis (FTA) 
A decision was made to use the What-If/Checklist methodology as it appeared to cover the 
greatest number of probabilities in which a release could occur and was more suitable for group 
analysis.   Since all members of the team are well versed in the operation of ammonia systems,  
prior experience with Ammonia PSM Process Hazard Analysis development was a major plus 
for the team as one member developed and implemented PSM 
programs during previous 
employment with another company.   The equipment in the PHA generic scenarios had to be 
tailored and specifically identified using in-house designations.  Each scenario followed the 
below format: 
     - Equipment: describes the equipment or activity for which a particular scenario  
     - Question: a question on which the scenario and consequence is based.  
     - Scenario: serves to identify an event associated with the question. 
     - Consequences/Hazards: indicates the possible impact on employees or equipment. 
     - Engineering/Administrative Controls: any controls which would mitigate the  
                 hazard.  (Routine operator inspections during rounds is an example of an  
                 E/A Control.) 
     - Risk Matrix analysis:   
         -- C (Consequence): a column to record the consequence ranking from a       
         qualitative analysis. 
         -- F (Frequency): a column to record the frequency r 
anking from a qualitative  
         -- R (Risk): a column to record the risk assesment degree from "A" (most severe)  
              to "D" (least severe) from a qualitative consequence and frequency  
    - Recommendations: Essentially, where no E/A Controls are present and the degree of  
    risk should warrant some control, then a recommendation is entered in the PHA    
    Recommendations section.        
Using the above format, team members analyzed a wide variety of scenarios in the following 
functional ammonia refrigeration areas; 
    - Compressors 
    - Condensers 
    - Air Purgers 
    - Pressure Vessels 
    - Evaporators 
    - Piping and Valves 
    - Pumps 
    - Instrumentation 
    - Start-up of systems 
    - Shut-down of systems 
    - Emergency operations 
    - Charging NH3 system 
    - Pump-out of NH3 system 
    - Human factors 
    - Facility siting 
    - Identification of past incidents 
The PHA took a 
week to accomplish once the groundwork was in place.  A number of morning 
working sessions were held as that time proved the most beneficial.  Each session was very 
intense and lasted several hours.  In general, each study had to take into account the potential for 
a hazardous situation to occur given the current environment in our plant.  The bottom-line 
question at the root of each scenario was, " what is the likelyhood of a release with our present 
E/A controls?"  This was the underlying thought process of each member throughout the entire 
study.  Once complete, a management system was developed to address, resolve, and document 
recommendations from the study.          
d.   Operating Procedures:   Standard Operating Procedures (SOPs) were developed for 
equipment and system functions to include normal start-up and shut-down, emergency shut- 
down, maintenance procedures, etc.  Procedures include photographs of key valves and valve 
identification using valve tags.  Since OSHA requir 
es employers consult with employees in the 
development of PSM, it was only logical for operators of the ammonia system to play a key role.  
The Lead Utility Engineer, one of Pearl Brewing's most experienced operators, played a 
significant part in the development of our SOPs.  The contractor incorporated our drafts into a 
well-organized and "user friendly" set of manuals.  SOPs serve several valuable functions.  First, 
they reduce the probablility of operator error.  Secondly, they provide a new operator with 
readily available references to assist break-in.  Much has to be remembered by the new 
employee during the break-in process.  If any element of the break-in process can be put in 
writing and easily accessed, then the likelyhood of mistakes is reduced.   Lastly, they create a 
proven operational method which can be reviewed periodically for accuracy and validity, also a 
requirement of PSM. 
All operators of the ammonia system have a full understanding and good overview of the process 
and principles of refrigeration.  SOPs deal with specific tasks related with the operation of the 
ammonia process.  An SOP has two specific areas to address; 
(1)  procedures for routine and emergency operations, and 
(2)  procedures for relevant tasks such as maintenance.   
Typical procedures for routine and emergency operations include,  
    - start-up, 
    - normal operations, 
    - temporary operations, 
    - emergency shut-down, 
    - normal shut-down, and 
    - start-up following an emergency shut-down. 
Typical procedures for maintenance activities of include, 
    - draining refrigerant oil, 
    - purging non-condensibles, 
    - pump-out (evacuate) to ensure all liquid is removed to reduce pressure within the piece  
      of equipment.  Equipment must be down to a vacumn as this procedure is essential to  
      safely open the equipment so that little or no refrigerant escapes to the atmosphere and  
             creates a  health hazard. 
Operating procedures were 
developed to cover safe work practices, such as Lockout/Tagout, 
Hot Work Procedures, and Confined Space Entry.   
    Lockout/Tagout - Detailed procedures are developed to electrically and mechanically 
isolate a piece of equipment for personnel to safely perform maintenance functions.  Each piece 
of equipment is identified as to Equipment Inventory Number, Location, and Energy Sources. 
In order for an equipment to be safely locked out, all energy sources must be isolated.  Possible 
energy sources are; 
    - electric, 
    - steam, 
    - stored energy, 
    - pneumatic, 
    - hydraulic, 
    - ammonia, and 
    - carbon dioxide. 
The energy sources are identified for equipment to be locked out.  The energy source location 
provides the exact physical location in the plant to find and effect the lockout.  The procedure to 
lockout and/or tagout provides the required actions necessary to isolate the equipment.  
Maintenance personnel should start work only after an attempt is made to s 
tart the machine.  If 
the machine fails to start, then the lockout is satisfactory. 
    Hot Work Procedures - (See Hot Work Permits, paragraph i). 
    Confined Space Procedures - This facility contains a large number of vessels which 
require atmospheric testing prior to entry.  A confined space is defined as a space which is not 
normally occupied, has restricted entry,  and could present a health hazard if entered without 
necessary safeguards in place.   All confined spaces are identified with a placard at or near the 
point of entry.   Confined space entry requires a check of the atmosphere for oxygen levels and 
presence of combustible and toxic gases.  Knowledge of the process is important to determine 
which hazards may be present.   No entry into a confined space is made without proper 
personnel protective equipment (respirator) unless the atmosphere contains sufficient oxygen 
and/or devoid of any potentially harmful gases.   Detectors for oxygen, combustible and toxic 
gases are  
used to read levels.  Thorough venting, either with natural or mechanical means, is 
employed to ensure the atmosphere is safe to enter.   As a confined space is made ready to enter, 
a safety observer must be posted at the access with visual or other means of communication.   
Our Confined Space Entry permits contain all the requirements necessary to conduct a safe entry 
e.   Training:    All operators of the ammonia system require thorough training.  A 
comprehensive break-in period is required prior to an operator being allowed to stand a shift 
solo.  Many of the operators have extensive experience with this ammonia refrigeration 
installation or with prior facilities from past employment.   Training involves a combination of 
formal classroom, hands-on, and OJT.  Training material included IIAR video training modules, 
NIOSH Safety and Health Manual, North American Emergency Response Guide, Spill 
Prevention Control and Countermeasures and Storm Water Pollut 
ion Prevention Plan, Sensidyne 
Gas Detector as well as locally prepared hand-outs on the plant refrigeration systems,  Each 
operator has received training in the below areas of ammonia refrigeration: 
    - Understanding MSDSs. 
    - Ammonia properties, safety and health hazards. 
    - The refrigeration cycle, how the plant operates. 
    - Each plant component (i.e. compressors, pumps, 
       evaporators, receivers, control valves, etc.) 
    - Mechanical integrity program requirements. 
    - Identifying and correcting abnormal operating conditions. 
    - Process Flow Diagrams. 
    - Routine refrigeration system operation. 
    - Individual's role in the emergency response plan. 
    - Emergency and normal refrigeration safety procedures. 
    - Ammonia Process Safety Management  
f.   Contractor Qualification: The primary purpose of this element is to ensure contractors are 
fully aware of the dangers of a system covered under Process Safety Management (PSM).   This 
section app 
lies to all contractors performing any type of maintenance or installation projects on 
the ammonia system.  It does not apply to contractors performing a service, such as janitorial or 
food, for example.  Contractors are required to train and inform their employees.  
Contractor selection: 
    - We implement a selection process involving bids on work directly associated with the  
    ammonia refrigeration system. 
    - Previous working experience with ammonia systems is the first requirement.  However,  
    as long as the contractor can demonstrate technical and procedural knowledge of       
    ammonia systems and Process Safety Management program elements then due     
    consideration will be given. 
    - A contractor's past safety record and current safety programs are taken into account in  
    the selection process. 
    - If the contractor has worked for Pearl Brewing in the past and the work was similar to  
    that which is currently bid, then an evaluation a 
nd bid acceptance may be based upon        
    such performance.  
Contractor awareness: 
    - Hazards of the ammonia system are identified during the job walk-through. 
    - Review piping color codes to familiarize contractor with the ammonia system. 
    - Review safety practices for presence, entry and exit of contractor's employees. 
    - Review facility emergency response plan to include egress routes and muster area  
    in the event evacuation is ordered. 
    - Each contractor employee must acknowledge receipt of this information.   
Contractor follow-up: 
    - It is necessary to periodically evaluate the contractor's adherance to PSM and other  
    safety elements. 
    - An illness and injury log related to the contractor's employees is maintained on-site. 
g.   Pre-Start Up Safety Review: The purpose of the Pre-Start Up Safety Review is to ensure 
that all considerations are addressed prior to admitting ammonia to the process.  PSRs are 
required for all new faci 
lities and for modifications to existing facilities that result in a change to 
the process safety information. 
New Facilities: (Pearl Brewing is not a new facility, however the following is for information 
purposes only and not applicable.)  
    - All information regarding a new installation needs to be incorporated into the Process  
    Safety Information of Ammonia PSM.  The information will be made readily available to 
    employees upon request. 
    - A Process Hazard Analysis will be conducted to identify any unique hazards associated  
    with the new installation.   All recommendations from the PHA should be resolved prior  
    to start-up. 
    - Construction and materials must be in compliance with current codes. 
    - All operating, maintenance, and emergency procedures must be documented and  
    implemented.  Standards, codes and manufacturer's instructions are to be part of this  
    - Training on the new equipment or installation must be documente 
Modified facilities: 
    - Update the Process Safety Information. 
    - Management of Change initiative documentation should reflect whether change is  
    major or minor, temporary or permanent. 
    - Update operating, maintenance and emergency procedures.  
    - Initiate training program for the modification. 
    - The Pre-Start Up must follow guidelines set forth by PSM.  A one page summary form  
    is used to verify compliance with the PSR 
h.   Mechanical Integrity:   Purpose is to ensure components are in good working condition and 
are leak free.  This element, however, is implemented on a daily basis with operators making 
routine rounds, documenting discrepancies through a plant work order procedure and corrective 
action follow-up.  A team comprised of contractor and plant personnel walked every ammonia 
line and inspected each piece of ammonia equipment to include compressors, pumps, 
condensers, evaporators, shell and tube heat exchangers, vessels, piping and sy 
stem elements in 
general in accordance with IIAR (International Institute of Ammonia Refrigeration) inspection 
sheets. In addition, sections of in-service piping were removed to evaluate serviceability.  All 
sections were deemed satisfactory and not in need of replacement.  Documentation for the 
record is maintained on-site and available to all personnel.  
i.    Hot Work Permits:   Cutting, welding, burning, or any use of an open flame operations pose 
a special problem as all ammonia equipment must be thoroughly pumped out or evacuated prior 
to welding or cutting.   The procedure covers any type of operation which could be a source of 
ignition.   All employees and contractors are required to use hot work permits.   This 
requirement is well understood by maintenance personnel and operators.  Pressure in the vessel 
or piping indicates a potentially explosive situation.  Only when the pump out gauge indicates a 
sub-atmospheric pressure in that part of the ammonia system should maintenanc 
e begin.  In 
addition to pump-out requirements, a fire extinguisher must be nearby, the immediate area must 
be checked for presence of combustibles, and one person must remain to act as a fire watch until 
no danger of fire exists.  A fire watch is required where there is the possibility that a fire might 
develop due to stray sparks, where there are wall or floor openings within 35 feet, or where there 
is the presence of combustibles within 35 feet of the hot work.   The hot work permit contains 
numerous safety precautions which must be considered prior to, during and after cutting or 
welding operations are completed.   The hot work permit details the precautions necessary for 
the safe conduct of hot work operations.  The following is a brief summary of what steps are 
required to execute a hot work permit requirement: 
    1.  The need for a hot work permit is identfied.  This may be indicated verbally or in  
    writing by in-house crafts or a contractor.   The need for a hot work pe 
rmit arises if it is  
    deemed that the work is located in an area where combustibles may be present, a       
    machinery space, or any area in which the present of open flame could pose a problem.   
    2.  The maintenance supervisor has responsibility to inspect the space where the work  
    is to take place and fill out the hot work permit. 
    3.   Hot work permits are valid for periods of no longer than 8 hours.  It contains the  
    name of the maintenance personnel, along with one individual designated as the fire  
    watch, if required.   
    4.   The maintenance supervisor reviews the list of general precautions with     
    personnel performing the work and identifies any unusual conditions which might call  
    for special attention.  The permit is signed by the supervisor and maintenance personnel  
    and posted at the site or on the equipment. 
    5.   The fire watch should remain 30 minutes after the work is completed and return t 
    the site 2-4 hours later as sometimes smoldering fires take that long for a fire to become  
    6.   The supervisor will sign the hot work permit once the work is complete. Permits are  
    retained for 30 days.  Hot work performed within the crafts's shops, such as the      
    pipefitters' shop or the machinists' shop does not require a hot work permit as those  
    areas are designed for and have the necessary safeguards in place for cutting, welding,  
    brazing or any open flame operations.  
j.   Management of Change:   With the addition of new equipment or any change which is not a 
"replacement in kind", a thorough evaluation takes place to ensure unrecognized or 
unacceptable hazards are not introduced to the process.   Changes are necessary to improve the 
process, replace defective or outdated equipment or to increase capacity.  The purpose is to 
ensure significant changes warrant proper review beforehand.  The Management of Change 

MOC) procedure is intended to apply to all ammonia related equipment and system 
components, regardless of whether it is major or minor, or of a temporary or permanent nature.  
Examples of changes which are subject to MOC initiative (This list is not intended to be 
    - Installation of a by-pass around a piece of equipment. 
    - Piping changes. 
    - Installation of a parallel piece of equipment. 
    - Replacement of a control valve of a different size or rating. 
    - Replacement of a gasket of a different material. 
    - Replacement of a vessel of different pressure rating. 
    - New construction. 
    - Change in operating parameters. 
    - Increase in ammonia inventory. 
    - Change in process variables, such as flow, temperature or pressure. 
A Management of Change initiative is not required when the change is a "replacement in kind".  
Examples would be: 
    - "Like for like" such as a 450 lb/hr carbon dioxide condenser with a 450 lb/hr carbon  
ide condenser from a different manufacturer, as long as piping and instrumentation  
    configurations are the same. (Ammonia is used in the liquifaction of carbon dioxide gas.) 
    - "Like for like"such as a 250 Ton Ammonia Compressor from the same manufacturer. 
    - Any change which does not impact the Process Safety Information. 
The procedure for MOC is as follows: 
    1.    A Management of Change Form (MCF) is initiated indicating priority, reason, and  
    technical description of the change. 
    2.   The MCF is reviewed by the Maintenance Supervisor for "replacement in kind",  
    major or minor, temporary or permanent change.  
    3.   If the assessment does not fall within the definition of change and thus is a    
    replacement in kind, then review, approval and disposition is outside the scope of this  
k.   Incident Investigation:   A formal investigation is required in the event of a major 
catastrophic release.  By definition, a catastrophic rel 
ease is a major uncontrolled emission, fire, 
or explosion involving ammonia that presents a serious danger to employees, contractors 
working on-site, or to off-site neighbors.   An incident investigation examines source of the 
release, causes (design shortcomings, corrosion, inadequate maintenance, process upsets, etc.).   
Also, what changes will take place to prevent future releases must be addressed in the 
investigation.  The following is a list of criteria that is use to determine whether an incident 
investigation should be made: 
    - Quantity of ammonia released. 
    - Injuries or death. 
    - Fire or explosion. 
    - Property damage. 
The following outlines an incident investigation procedure: 
    1.  Initial incident response. 
    2.  Establish Investigation Team. 
    3.  Determine the facts. 
    4.  Determine the cause. 
    5.  Recommend results/follow-up. 
    6.  Communicate results/follow-up. 
l.   Emergency Planning:   An Emergency Response Plan identifies perso 
nnel, procedures, 
equipment, federal, state, and local notification requirements, coordination with outside 
assistance (fire department, HAZMAT) etc. should a major release occur.  A critical element to 
discuss is the importance of the Incident Command System.   Why use an Incident Command 
System?  First and foremost, this system provides a clear structure for the diverse activities 
taking place during a major uncontrolled release.   Twenty-three salaried and hourly personnel 
have received training in Hazardous Waste Operations and Emergency Response (40-hour 
course) at our facility.  All personnel are familiar with the requirements and provisions of the 
Incident Command System.    
What does the Incident Command structure accomplish? 
    - Emergency response personnel are confronted by a number of safety hazards during an  
    emergency.   This system helps ensure that actions taken at an incident are effectively  
    controlled and that the risks and benefits of various alternati 
ve courses of action are  
    evaluated on an ongoing basis.   This organized approach helps to ensure that the safety  
    of forces operating at an emergency is not comprised.   An important part of this     
    structure assists accountability and status of all personnel at the scene.  
The Incident Command System ensures that someone is always in charge. 
    - A single person must be in charge at the scene.  Imagine the confusion if no one or  
    more than one person assumes control.  An organized command structure is a well  
    recognized function of successful groups of people striving to accomplish common  
    goals and objectives.  By having one person in charge, major pitfalls are avoided.  The  
    incident scene will not quickly deteriorate into chaos and information passed to    
    responders will be recognized as having originated from the acknowledged authority.    
The Incident Command System conforms to Laws and Standards. 
    - The Superfund Amendments a 
nd Reauthorization Act of 1986 (SARA) requires that  
    emergency response organizations handling hazardous materials incidents operate with  
    an Incident Command System.   In addition, Occupational Safety and Health   
    Administration (OSHA) and Environmental Protection Agency (EPA) mandate use of  
    Incident Command Systems as well. 
The Incident Command System efficiently utilizes resources. 
    - It is important that the resources for stabilizing and controlling the incident be used  
    efficiently and provide the structure for managing these resources.  These resources  
    include personnel, apparatus, specialized equipment, materials, and facilities required to  
    deal with the emergency. 
Responsibilities of the Incident Commander 
There are six responsibilities Pearl Brewing Company expects an Incident 
Commander to assume: 
1.   Make an Initial On-Scene Assessment and Evaluation. 
    -Carefully evaluate the situation.  Are lives in jeopardy?  What is the  
hazard?  What 
property is at risk?  What resources are available?  What can be done to safely control the 
2.   Determine Actions. 
    - After the initial evaluation is made, a fundamental decision mus tbe made...whether to 
approach stabilization and control from an offensive or defensive mode.   Where lives are at risk 
and where prompt safe control is probable, offensive actions are appropriate.  In an incident 
involving little or no life hazard or where the size of the incident, chemicals, or lack of 
appropriate resources preclude prompt stabilization, defensive action is warranted. 
3.   Determine Additional Resource Requirements. 
    - Our Incident Commanders are taught that in severe situations initial response resources 
may not be adequate to attain stabilization.   One of the most important functions of the Incident 
Commander is to determine resource needs and initiate requests for additional support. 
4.   Deploy Personnel and Units. 
    - An integral element of  
deploying personnel and units is issuing specific, objective- 
oriented assignments.  Our response concept involves, depending on the size of the release, a 
request for support from Eagle Construction and Environmental and possibly the Fire 
Department which would result in a large number of on-scene assets. 
5.   Establish a Command Post. 
    - During the initial evaluation, the Incident Commander may have to move around in 
order to gather information.  In all but the most minor incidents, a formal, stationary command 
post is necessary, located in a safe area and easily visible. 
6.   Transfer of Command. 
    - As an incident evolves, it may be necessary to transfer command to a more experienced 
professional.   This is a transaction between two parties.  It is the duty of the incumbent to brief 
the oncoming Incident Commander on the action plan in effect, status of resources and/or any 
unusual safety problems being encountered.  Upon arrival of the HAZMAT team on-scene 
commander or  
the Fire Chief, command will transfer to one of these individuals from the Pearl 
Brewing Incident Commander. 
7.   Activities During Termination. 
    - As incident planning, operations, clean-up, logistics and finance wind down 
disengagement and termination may take place over a considerable period of time.  Transfer of 
command would pass "down" rather than "up" as in the initial stage of the incident.   Hazardous 
materials incidents are not considered under control until the spill, leak or fire has been 
contained.  Decontamination of personnel is a major issue to be dealt with during termination.  
There are certain legal and political concerns, jurisdictional disputes, length of time a major 
highway should remain closed or status of personnel displaced from their homes or busineses.  
Finally, a complete accounting of the incident must be made and attention to this detail can be 
given during termination.   
8.   Summary. 
    - Hazardous materials incidents could present many unfore 
seen problems.   A well- 
structured Incident Command system applies to small, as well as large releases.  Pearl Brewing 
Company realizes the importance of sound training and coordination with outside agencies. 
m.   Compliance Audit:   Every three years the program is subject to examination to ensure all 
provisions meet compliance.   A compliance audit is conducted by a party knowledgable with 
the process and familiar with the PSM elements.  Documentation review and personal interviews 
comprise the bulk of the audit. 
n.   Trade Secrets:   A company or firm may not withhold information to prevent establishment 
of a PSM program.  Typically, no trade secrets exist which would prevent development of a 
PSM program, since ammonia refrigeration principles of operation are universal and well known 
and fall into the category of utilities support.  The Trade Secrets element of PSM is more 
directed to those aspects of a company's production process or service which solely may need to 
be safeguar 
5.    Five Year Accident History -  
    The company has had no reportable accidents within the past five years. 
6.    The Emergency Response Program -   
     Pearl Brewing Company emergency responders completed a 40-hour HAZWOPER 
(Hazardous Waste Operations and Emergency Response) training program for selected salary 
and hourly personnel which included a response scenario and drill.   The training was conducted 
on-site with classroom, hands-on and actual in-plant exercises by Safe-T-Train, Inc.  
Coordination with Eagle Construction and Environmental, Inc. ensures if an outside assistance 
team (HAZMAT) is necessary to contain a major release, additional support would be available 
within minutes.  Eagle Incident Commanders and corporate representatives conducted a plant 
walk-through to become familiar with the facility, in general, chemicals in use, equipment 
arrangements, egress routes, etc.   In the event a reportable incident occurs, emergency 
notification phone number 
s are in place to alert federal, state, and local authorities.   Elements of 
an Emergency Response Plan should include: 
    - Pre-emergency planning 
    - Personnel roles, lines of authority, training and communication. 
    - Emergency recognition and prevention. 
    - Safe distances and places of refuge (muster areas). 
    - Site security and control. 
    - Evacuation routes and procedures. 
    - Decontamination. 
    - Emergency medical treatment and first aid.  
    - Emergency notifications. 
    - Critique and follow-up. 
    - Emergency equipment. 
7.   Planned Changes To Improve Safety -               
With the approach of hot, humid weather and the resultant additional load on the refrigeration 
system, plant maintenance personnel have invested much effort into overhauls of several 
ammonia compressors, repair/replacement of purge point solenoids, cleaning louvres, strainers, 
spray nozzles, replacing and tightening fan belts, etc. on the ammonia evaporative condensers.  

roper operation of ammonia system components is essential to reducing risk of release.   With  
recent replacement of certain ammonia liquid metering devices, strainers and level controls on  
the carbon dioxide liquifaction system undertaken last fall, the ammonia system is in the highest 
state of operational safety and readiness ever.  Other than routine replacement of any defective 
or unserviceable components, as discovered by our operators or maintenance personnel, no major 
changes are anticipated in our ammonia refrigeration system.
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