United States Cold Storage, Oakland - Executive Summary
United States Cold Storage, Inc. is committed to the safe operation of all our facilities to protect our workers, the public and the environment. This is accomplished to a great extent by a well developed, up-to-date and implemented Risk Management Program. All USCS facilities shall operate in a prudent and safe manner. It shall be the responsibility of the plant manager to ensure that all procedures are followed as set forth in our Risk Management and Process Safety Management programs. In the unlikely event of an accidental release it is USCS policy to immediately call the National Response Center, Local Emergency Response Committee, the local Fire Department and other agency(ies) that may be required. All USCS facilities will have an emergency response team to assist these agency(ies). |
United States Cold Storage, Oakland is a public refrigerated warehouse that uses anhydrous ammonia as a refrigerant in a closed loop system. Anhydrous ammonia, most commonly known as ammonia, is an e
xcellent refrigerant and is commonly used in most of the world's industrial refrigeration systems. Ammonia has an excellent warning property, its odor. Ammonia's odor is familiar to most people due to the fact that it is commonly used in household cleaning solutions. Ammonia can be detected as low as 5 parts per million (PPM) and has an average life span of 7 days in the environment before it breaks down to its common elements nitrogen and hydrogen.
Typical items stored within USCS facilities are raw or processed food items that can be found in your supermarket or local restaurant. Temperatures range between -30 degrees to +45 degrees F. The refrigeration equipment and pipinf are located throughout the facility. The condensers and related piping are on the machine room roof with the piping to and from the freezers, coolers, truck and rail docks located on the warehouse and dock roofs. The machine room contains most of the large refrigeration machinery and vessels. In an unlikely e
vent of a refrigerant leak in a refrigerated space, the ammonia vapor would be contained inside the space, due to the vapor tight construction of the facility. It then may be treated and/or vented under controlled conditions. The facility is equipped with ammonia detectors throughout to help lessen any leaks that might occur and to provide an early alert.
USCS believes that prevention is foremost. All of USCS facilities are maintained by a staff of trained maintenance personnel. Most of these people are members of the Refrigerating Engineers and Technicians Association (RETA) and all Chief Engineers are members of the International Institute of Ammonia Refrigeration (IIAR) and hold a RETA Certification Level A. USCS has on staff at the corporate level an OSHA and EPA coordinator/trainer who is a certified OSHA Instructor. All facilities comply with OSHA's Process Safety Management without regard to the ammonia threshold quantity.
The facility's emergency response program is base
d on the OSHA requirements for 29 CFR 1910.38-Emergency Action Plan, OSHA's 1910.119, Process Safety Management and 1910.120 HAZWOPER standards. We have trained employess for emergency response and maintain a written emergency response plan.
FIVE-YEAR ACCIDENT HISTORY:
The Oakland facility has been operating at this location for the past 50 years. Within that long history the facility has seen few refrigerant releases. Since June, 1994, this facility has not experienced any accidents or releases from their refrigeration system(s) that resulted in deaths, injuries or significant property damage on site or offsite, deaths, injuries, evacuations, sheltering in place, property damage or environmental damage.
OFFSITE CONSEQUENCE ANALYSIS:
Worst-case release scenario analysis: As required by law under Title 19, Public Safety, Chapter 4.5 California Accidental Release Prevention Program, Section 2750.3, and 40 CFR Part 68.25, Worst-case release scenario analysis, an analysis was prepared
for the Oakland facility. The United States Environmental Protection Agency's Risk Management Program Comp was used for this analysis. This worst-case release scenario is estimated to create the greatest distance in any direction to an endpoint of 200 ppm from the accidental release of anhydrous ammonia used as a refrigerant in a closed-loop refrigeration system. The quantity release was based on a "Worst-case" release scenario for a toxic gas liquified under pressure that is normally a gas at ambient temperature. The release was generated from the facility's Blast Freezer Surg Drum. Releasing 438 pounds per minute for a 10 minute period with passive mitigation system in place, the release was inside the facility. The Oakland facility has offsite consequence.
The dispersion analysis used a wind speed of 1.5 meters per second and an "F" atmospheric stability class. With an ambient temperature of 77 degrees F (25C) and a relative humidity of 50%. Using a release height at ground level
and a surface roughness class of Urban. Dense gas was used for gas density.
Alternative Release Scenario Analysis: As required by law under 40 CFR Part 68.28, Alternative release scenario analysis was prepared for the Oakland facility. The United States Environmental Protection Agency's Risk Management Program Comp a computer dased program for Ammonia was used for this analysis. This alternative release scenario is estimated to create a distance to reach off-site in any direction to an endpoint of 200 ppm from an accidental release of ammonia used as a refrigerant in a closed-loop refrigeration system. The Oakland facility has offsite consequence.
The alternative release scenario was piping failure for the evaporative condenser. The piping failure was identified through the review of our process hazard analysis (PHA) for the Oakland facility's What-If Study. The failure scenario was identified under Subsystem(s) # 9 Evaporative Condensers. No Passive mitigation system was in place.
The following administrative controls are in place: Engine room log is maintained with visual checks of all of the equipment including the condenser. Refrigerant that is added to the refrigeration system is noted on the Daily Engine Room Log. Annual preventive maintenance of the refrigeration equipment includes the condenser.
The second PHA recently performed for this facility produced six recommendations to improve safety. Such recommendation included installation of new mitigation and/or controls, equipment and/or technology.