Otto & Sons, Division of OSI Industries, Inc. - Executive Summary |
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Otto & Sons is a food processing facility located at 4545 South Racine Ave., Chicago, IL. The regulated substance under the RMP Rule is Anhydrous Ammonia used as a refrigerant to maintain temperature in the facility's production and storage areas. The facility maintains 21,000 lbs of Anhydrous Ammonia on site as an operating level for the ammonia refrigeration system. Worst-case Scenario: The worst-case release scenario would be the rupture of the high pressure receiver, with a maximum inventory of 13,250 pounds. The receiver is located on the roof of the facility, so no passive mitigation was considered. The offsite endpoint distance was determined using EPA's "RMP Guidance for Ammonia Refrigeration" reference tables and equations, and was calculated at 1.5 miles. Alternative release scenario: The alternative release would be the lifting of a relief valve. The offsite endpoint distance for this scenario was calculated to be 0.10 miles. Census information for both scenario s was obtained using "Landview III" software. Accidental Release and Emergency Response Policies: Otto & Sons has established an in-house emergency response team, and has an outside contracted emergency response team, to quickly respond to and handle releases of Anhydrous Ammonia. The established steps include initial training under the OSHA regulation 29 CFR 1910.120 HAZWOPER. The facility has also established annual retraining for all personnel that are on the HAZMAT Team as well as periodic spill drills and plant wide evacuation drills to assure all employees are prepared in the event of an emergency. Otto & Sons has also established training with the Fire Department personnel and community Local Emergency Planning Committee. These established plans and procedures shall be periodically reviewed to assure that they are current and up to date. Emergency Response Program: Otto & Sons has developed an emergency response plan to provide notification and evacuation of the facility and the surrounding community. The plan also outlines procedures for mitigating and neutralizing the affected personnel as well as the community. Otto & Sons has trained the refrigeration operators and selected production and office personnel in Hazardous Waste Operation and Emergency Response 29 CFR 1910.120. The trained personnel will assess each release situation and determine the appropriate emergency response to initiate. Otto & Sons has established written operating procedures for all aspects of the ammonia refrigeration system, including procedures Emergency Shutdown and Isolation in the event of a release. This team will coordinate their efforts with the outside emergency services, including the Chicago Fire Department and the Cook County Emergency Planning Committee to assure the safety of all. Five Year Accident History: We have had three accidental releases of ammonia in the past five years; the largest release was estimated at 300 pounds. There were no offsite injuries or evacuations as a result of these releases. General Accidental Release Prevention Program and Chemical Specific Prevention Steps: Otto & Sons has not only complied with the EPA Risk Management Program but also the OSHA Process Safety Management regulation to assure that the Ammonia Refrigeration System is well maintained and employees are properly trained and periodically retrained to assure they are kept up to date on any changes and new operations that may effect them. In addition, to maintain the mechanical integrity and safety of this process, this facility follows the following industry codes and standards: ASME Boiler & Pressure Valve Codes ANSI B31.3 Piping Code IIAR industry guideline for safety and good engineering practices NFPA guidelines for fire protection equipment Planned Changes to Improve Safety: Through regular audits, training, maintenance, testing and inspection programs Otto & Sons has established a history of safe operation and that community emergency actio n plans are current and training with community services is done for a safe response in the event of an accidental release. |