otto & sons, Division of OSI Industries, Inc. - Executive Summary |
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otto & sons, Division of OSI, Inc. 4980 West 9470 South West Jordan, UT, 84088 Accidental Release Prevention and Emergency Response Policies: otto & sons, West Jordan is committed to environmental, public safety, and employee safety. otto & sons has implemented training (HAZWOPER) and programs (Process Safety Management, Risk Management Plan) in an effort to minimize the occurrence of a chemical incident. otto & sons conducts annual training drills for all employees in evacuation and emergency response. Awareness training has been coordinated with the West Jordan Fire Department and Salt Lake County HAZMAT. No accidental release of ammonia has occurred since the installation of the ammonia freezing system in June of 1995. otto & sons process: otto & sons West Jordan is a producer of frozen meat products. otto & sons West Jordan is a producer of value added meat products and uses a closed-loop ammonia freezing system to quick-freeze different meat products. otto & sons has 18 ,000 pounds of Anhydrous Ammonia onsite. Worst-case scenario and alternative-case scenario: A worst-case scenario could be a rupture of the high-pressure receiver. The maximum operation level, and therefore amount released, is 9020 pounds. A worst-case scenario release would have offsite impact. The calculation to endpoint using RMP*Comp is a 1.2 mile radius. An alternative-case scenario could involve a rupture disk / relief valve failure. The ammonia released in this scenario could reach an endpoint radius of 0.10 miles according to RMP*Comp. Landview software was used to calculate the census data. Five year accident history: None General accidental release prevention program and chemical-specific prevention steps: otto & sons West Jordan has a written program in compliance with OSHA regulations in 29 CFR 1910.119 (Process Safety Management or PSM). The PSM program outlines start-up and shutdown procedures for safe operation of the ammonia freezing system. The PSM pr ogram procedures are followed to prevent the accidental release of ammonia from the freezing system. The ammonia system was designed and built with multiple safety features and redundancy as added precaution. Emergency procedures for shutdown and isolation of an ammonia leak are explained and practiced in the PSM program. Process Safety Information (PSI) is available for all employees. PSI includes MSDS sheets, summary of physiological effects, ammonia affected areas and chemical inventory. This information is readily available for all employees. Process Hazard Analysis (PHA) has been completed for the ammonia system. An outside consultant was hired to assist in the PHA process. The analysis revealed several items that could be improved. Each item was reviewed and fixed accordingly. Standard Operating Procedures (SOP's) are written and used for system start-up and shut down. The SOP's outline the correct and safe order for operating the ammonia system. Additions to the curre nt system will require written SOP's be in place for operation. Employee training follows guidelines in accordance to HAZCOM. Annual refresher training occurs for all employees. Mechanics who operate the ammonia system receive training according to 29 CFR 1910.120 and annual refresher training. Contractors who work on the ammonia system are required to have the training according to 29 CFR 1910.120. Prestart-up review: A prestart-up safety review will be performed for any added equipment to the ammonia system. This review will assure that all safety measures, equipment SOP training, and construction has been completed. Mechanical Intergrity: SOP procedures have been established to inspect and maintain the mechanical components on a regular basis. The Emergency Action Plan involves first responders trained to assist the fire department and HAZMAT teams. It includes communication with Salt Lake County LEPC and local agencies regarding an accidental release. The plant employees pa rticipate in annual evacuation drills in order to effect a rapid evacuation. Incident Investigation: An investigation team following the investigation procedure will review any incident or near misses. The results will be recorded and used for any needed changes to the system. Management of change procedures are written for the ammonia system. Any additions to the ammonia system will be evaluated using the PSM process to determine the effect on the current ammonia system. The PSM evaluation for the any new addition will be used to update current SOP's, inspection processes, and management of change records. Compliance audits: Audits will be conducted every three years according to 29 CFR 1910.119. Emergency response program: Emergency response awareness has been coordinated with the local West Jordan Fire Department and Salt Lake County HAZMAT teams. Emergency evacuation drills are practiced for all employees. Mechanics who operate the ammonia freezing system receive an initial 40-hour HAZWOPER course and annual refresher courses. Planned changes to improve safety: otto & sons is committed to maintaining a safe ammonia freezing system. The current system uses state-of-the-art technology in design, construction, and safety features. New technology may provide safer and better protection against accidental release. New technology and training will be used as needed to maintain an excellent and safe ammonia freezing system. |