Spoetzl Brewery - Executive Summary

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The Spoetzl Brewery, located in Shiner, Texas, is a subsidiary of the Gambrinus Company Breweries.  The facility produces and bottles Shiner beer.  The ammonia refrigeration system is a utility system supporting the plant by providing space conditioning for beer/intermediates tank storage and various brewing process areas.  The system also provides cooling to generate chilled water or glycol through flooded heat exchangers which in turn supplies secondary media and/or direct product cooling. 
 
Ammonia contained within the refrigeration system is a regulated substance under both the EPA and OSHA regulations.  At the Spoetzl Brewery the maximum inventory of ammonia exceeds the regulatory threshold of 10,000 pounds. 
 
The Spoetzel Brewery is committed to protecting the public, its employees, and the environment from any accidental releases of hazardous materials used at its facilities.  We have implemented safety, environmental protection, and risk management programs to prevent hazardous m 
aterials releases.  
 
If there is an accidental release, we will immediately call for emergency response to minimize the effect of the release and notify the public of any actions necessary to ensure public protection, through the Shiner Fire Department. 
 
Worst-Case Release Scenario 
 
The Spoetzl Brewery has conducted an offsite consequence analysis as required by the EPA regulations, including an extremely unlikely, worst-case release scenario (i.e., total release from the single largest container over a ten minute period, assuming worst case meteorological conditions followed by an explosion of the resulting vapor cloud).  Results of this worst-case event indicate that offsite receptors would be affected.  
 
This type of release is not considered credible from the standpoint that an event of this nature would require the catastrophic failure of the container, resulting in a sudden release of the entire contents over a ten-minute period.  The ammonia system components are designed to wit 
hstand pressures well in excess of normal operating conditions and the Spoetzl Brewery maintains a very rigorous maintenance and prevention program for all ammonia process equipment. 
 
In fact, EPA release reporting databases and industry experience suggest that the worst-case release scenario as defined in the RMP regulations is so unlikely that it should not be used as the basis for emergency planning.  A more reasonable potential release scenario for emergency planning is presented in "The alternative release scenario(s)" section below. 
 
Alternative Release Scenario 
 
A "credible worst-case" scenario, formulated in accordance with USEPA guidance, was selected as the Spoetzl Brewery alternative release scenario. This scenario involves a one-inch diameter hole from a break in the high pressure liquid ammonia piping on the roof of the facility.   Results of this credible worst-case event indicate that there are some offsite receptors that would be affected.   
 
The results of the process  
hazard analysis (PHA) and the facility's operating history suggest that even this credible worst-case is extremely unlikely to occur, but it can serve as the basis for emergency planning.  
 
Accidental Release Prevention Steps 
 
The Gambrinus Company  is committed to public safety, personnel safety, continued reliable operation and regulatory compliance.  Based on this commitment, the Plant Engineer has assumed overall responsibility for the development and implementation of the Risk Management Program.  The Plant Engineer has also clearly defined accountability and responsibility for each of the prevention program elements to meet both EPA and OSHA Process Safety Management requirements. 
 
To ensure that a worst-case or alternative release scenario does not occur, the Spoetzl Brewery maintains a release prevention program with the primary focus of protecting the public and plant employees from the hazards associated with an accident or release involving anhydrous ammonia.  The multifacet 
ed program includes the use of: 
 
Ammonia gas detectors and alarms to rapidly alert operators to any problems; 
 
Process safety information to document the safe process design; 
 
Process hazards analyses to evaluate the chemical and process hazards; 
 
Operating procedures to ensure that the system is operated safely; 
 
Maintenance, inspection and testing to ensure that the system is maintained according to applicable standards and manufacturer's recommendations; 
 
Training, Hot Work Permits, Contractor Safety, and Employee Participation Programs to ensure that all employees and contractors working on and around the processes are aware of the hazards, can perform their job duties safely and know the actions to be taken in an emergency; 
 
Management of Change and Pre-startup Safety Reviews to ensure that changes are documented, analyzed and kept within the design basis; 
 
Incident Investigation procedure to investigate each incident and "near misses" to determine root causes and make needed safe 
ty improvements; and, 
 
Periodic Compliance Audits to ensure that our programs are working as they should to protect both the public and employees. 
 
Five-Year Accident History 
 
Within the past five years, the Spoetzl Brewery has not had any accidental releases that resulted in injuries or property damage. The plant has maintained an excellent safety record throughout its operating history and has never had a major anhydrous ammonia release that could have had adverse effects on the public.   
 
Emergency Response 
 
In the event that an ammonia release does occur, the Spoetzl Brewery has an emergency response program that coordinates emergency response with the Shiner Fire Department. If such a release did occur, plant personnel would contact the Shiner Fire Department, and contract responders, who would dispatch specially trained personnel to the facility.  
 
Maintaining A Safe Operation 
 
The Spoetzl Brewery continually works to safely manage the hazards of anhydrous ammonia to protect the  
community we serve and the employees working for us. The Risk Management Program will be maintained to reduce the risk of accidental releases and each year we will conduct training, review procedures, maintain the equipment and follow safe work practices. Periodically, we will audit our program, review our Process Hazard Analysis, and coordinate with the community emergency response organization.  During the review and revision just completed of operating procedures for the Spoetzl Brewery it was determined that this plant would benefit from certain refinements of those procedures.  Accordingly, we are undertaking a comprehensive effort to further upgrade the operating procedures so as to improve processes and work practices and to enhance the ability of plant personnel to assure safe and efficient control and management of the plant.
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