Fulton Market Cold Storage Co. LLC. - Executive Summary |
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Fulton Market Cold Storage Company, LLC. Risk Management Plan Executive Summary The administrative, management and operations staff at Fulton Market takes pride in being a part of the local community, and understands that responsibility and commitment are integral components to the privilege of being considered a good neighbor. To assure the preservation of this standing, the health and safety of the community, our employees and visitors, as well as the protection of the environment, are given first priority in all facets of our company operations. Through uncompromising adherence to high safety standards, and open and ongoing dialogue with community groups and local authorities, we hope to maintain and enhance the good relationship that we've enjoyed with all of our neighbors for many years. Regulated Substances at the Fulton Market Cold Storage Facility Fulton Market Cold Storage Company, located at 1000 W. Fulton Street, Chicago, operates as refrigerated warehouse for bulk and packaged food products. The warehouse portions of the facility are refrigerated by low-temperature, calcium chloride brine circulated through steel ceiling coils and similar, heat absorption devices. The heat absorbed by the brine is removed by a standard, two-stage anhydrous ammonia refrigeration system. In the this process, liquid anhydrous ammonia and calcium chloride brine are circulated through shell and tube chillers, with anhydrous ammonia in the shell and brine in the tubes. The anhydrous ammonia evaporates as it absorbs heat from the brine. The anhydrous ammonia vapor is subsequently drawn from the chillers, compressed to a high pressure, high temperature gas, and circulated through condenser coils located on the facility roof. Water and outside air are circulated across the exterior surface of the condenser coils, cooling the anhydrous ammonia and condensing it to liquid state. The anhydrous ammonia liquid flows through a pressure-reducing device and into a storage ves sel (receiver), from which it is supplied back to the chillers where the process is repeated as described above. Anhydrous ammonia (CAS No.7664-41-7) is listed as a regulated substance under EPA standards, and exposure to it through inhalation or physical contact is hazardous to life and health. Approximately 23,000 lbs of anhydrous ammonia is utilized in the facility refrigeration system. The refrigeration process does not require any additional introduction of anhydrous ammonia into the system beyond this initial charge quantity; that is, the ammonia in the system is reused with every refrigeration cycle, and there is no regular transferring of this substance in or out of the facility. Under normal operations, anhydrous ammonia is not released outside the system in any form or state. However, since portions of the system are maintained below atmospheric pressure, it is possible for microscopic amounts of air and non-condensable particles inherently contained in air to migrate in to the system through pump seals, valve packing, and similar system components. These contaminants are routinely removed by automatic purging system. Small amounts of anhydrous ammonia are removed along with the contaminants, and are diluted with water and discharged from the system into the facility waste water system as ammonium hydroxide (CAS No. 1336-21-6) in trace quantities. Under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the reportable release quantity of ammonium hydroxide is 1,000 lb. Ammonium hydroxide is not listed as a Hazardous, Extremely Hazardous, or Toxic Substance or Waste under EPCRA or under Section 112(r) of the Clean Air Act (CAA), or under the Resource Conservation and Recovery Act (RCRA). Under normal operating conditions, internal migration of lubricating oils occurs from mechanical components to other parts of the system. This oil must be removed periodically, and is manually drained by Fulton Market maintenance emp loyees following standard operating procedures outlined in the Fulton Market Process Safety Management program described below. The drained oil, which contains trace quantities of anhydrous ammonia, is stored in sealed containers and is periodically removed from the site by a licensed, hazardous waste-hauling contractor. Worst-Case Release and Alternative Release Scenarios In compliance with the requirements of the Environmental Protection Agency Risk Management Plan, worst-case release and alternative case release scenarios have been calculated to determine the degree to which an uncontrolled release of anhydrous ammonia at the Fulton Market facility would adversely impact the surrounding community and environment. The calculations were made following the EPA's Offsite Consequence Analysis (OCA) for Anhydrous Ammonia method. The selected condition for the worst-case release considers a rupture of the receiver vessel, located in the facility Engine Room, with the vessel filled to maximum capacity of 5,990 lbs of liquid anhydrous ammonia at 60 psig. It is assumed that the rupture is such that the all of the liquid will be drained from the vessel in a period of ten minutes, and the anhydrous ammonia will be released from the vessel at the rate of 5,990 lbs/minute. Impact on the surrounding community and environment is mitigated by the vessel's location within the facility Engine Room. The Engine Room has a volume of 95,000 cubic feet. It can be assumed that only a portion of the anhydrous ammonia will be in vapor or liquid droplet form and thus be airborne. Evenly dispersed, this portion will constitute approximately 1 lb. of anhydrous ammonia per 16 cubic feet. The remainder will collect in pools on the Engine Room floor, evaporating relatively slowly and contributing to the rate of release from the building to a lesser degree. * The Engine Room is mechanically ventilated. Assuming that all ventilation equipment is in operation at the time of release, resul ting in approximately 3 air changes per minute, the estimated release rate from the facility into the surrounding environment is approximately 170 lbs of anhydrous ammonia per minute. The OCA assumes existing meteorological conditions of a wind speed of 1.5 meters/sec., F stability class, 250 C. (770 F). outdoor ambient temperature and 50% humidity. Under these conditions, the area affected by the release will extend from the point of release at Fulton Market to a radius of 0.5 miles (toxic endpoint) in the surrounding community. The selected condition for the alternative case release scenario considers a flange failure, weld crack, valve stem leak, or gasket rupture in the ammonia condenser liquid return pipe line located on the roof of the facility. The anhydrous ammonia in this line is in a liquid state under a pressure of 180 psig. Assuming that the breach in the line is the equivalent of a 1/2" hole, the release rate into the surrounding atmosphere is estimated to be approxima tely 535 lbs per minute over a period of 10 minutes. For the alternative case scenario, the OCA assumes existing meteorological conditions of a wind speed of 3 meters/sec., D stability class, 250 C. (770 F.) outdoor ambient temperature and 50% humidity. Under these conditions, the area affected by the release will extend from the point of release at Fulton Market to a radius of 0.2 miles (toxic endpoint) in the surrounding community. Prevention Program Fulton Market has implemented a Process Safety Management program to help significantly reduce the possibility of an uncontrolled release of ammonia from the facility. The elements of this program correspond with all standards set forth in OSHA 29 CFR 1910.111 and EPA 40 CFR 68 Subpart D, and include consistent, proactive measures toward maintaining the integrity and safe operation of the refrigeration system. All employees involved in the operation and maintenance of the refrigeration system attend initial and refresher training courses focusing on the specific safety and health hazards of anhydrous ammonia, emergency operations, and safe work practices. The mechanical integrity of all system components is maintained by daily inspections and regularly scheduled preventive maintenance by the facility maintenance staff All employees and contractors are required to strictly adhere to standard operating procedures and safe work practices when operating or performing maintenance work on or in the vicinity of the refrigeration system. Automated engineering controls are incorporated into the refrigeration system, and are designed to provide early warning of incipient danger, or to actually disable the system if a hazardous or potentially hazardous condition develops. These controls include safety cutout devices, relief valves, and ammonia detection sensors. The detection sensors are electronically linked to an off-site, 24-hour monitoring system that immediately alerts the local emergency response agency upon ac tivation. Fulton Market has implemented a comprehensive Management of Change procedure by which all anticipated modifications to plant operations, structure and/or mechanical systems are thoroughly analyzed in regard to any potentially adverse effect they may have on safety of the facility occupants, the surrounding community, and the environment. As an added safety measure, virtually all refrigeration system components are located remotely and in sections of restricted access from the areas of primary activity at the facility. This significantly reduces the possibility of inadvertent damage to system components by forklift operations or other external causes. Five year Accident History There has been no accidental release of anhydrous ammonia at Fulton Market Cold Storage in the past five years. Emergency Response Program All employees involved in the operation and maintenance of the refrigeration system attend training classes that focuses specifically on responding to spills and uncontrolled releases of anhydrous ammonia. Response equipment, including negative pressure respirators, personal protective equipment, and a full assortment of tools are readily accessible to promptly abate and repair any incidental and minor releases of anhydrous ammonia. Fulton Market has developed a written contingency plan in conjunction with the Chicago Fire Department and the Chicago Emergency Planning Committee to address the occurrence of a significant release of anhydrous ammonia at the facility. Emergency notification procedures to response agencies and the community are clearly outlined in the plan, along with critical site and system information to control and abate a release. Planned Changes to Improve Safety As an active member of the International Association of Refrigerated Warehouses (IARW), Fulton Market has ready access to information on the latest technological developments operational safety. We plan to continue our proactive approach toward safety assur ance by continuing to explore all new ideas and improvements that may enhance our existing programs. |