Frozsun Foods, Inc. Santa Maria, Californina - Executive Summary

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Frozsun Food Inc., (Frozsun) operates a cold storage and fruit processing facility in Santa Maria, California (Facility).  The Facility is located at 1315 South Blosser Road at the southwest corner of the intersection of Blosser and Stowell Roads.  The Facility is owned by Western Refrigeration and has two separate refrigeration systems that use anhydrous ammonia (CAS No. 7664-41-7) as the working fluid. 
 
An accidental release of ammonia could potentially pose a health hazard to Facility employees and the surrounding community.  Frozsun is committed to the prevention and minimization of accidental releases of ammonia.  To meet their commitment to prevention, Frozsun has implemented an EPA Risk management Plan (EPA RMP) to address regulatory requirements from Section 112(r) of the Clean Air Act (CAA).   Based on the regulatory requirements, a Program Level 3 Prevention Program has been prepared with assistance and input from the Facility operators. 
 
The facility stores ammonia in two se 
parate sets of receiver tanks and in refrigeration piping, accumulators and associated refrigeration system equipment.  Frozsun estimates the quantity of ammonia at the facility is approximately 22,000 pounds.  The threshold quantity that triggers the EPA RMP is 10,000 pounds. 
 
There have been no reportable releases of regulated materials at the Faclity within the last five years.  As required by 112(r) of the CAA, the hypothetical worst case and alternate case release scenarios have been evaluated using parameters described in 40 CFR 68.25 and 40 CFR 68.28 and the EPA's Off-Site Consequence Analysis guidance document.  These analyses indicated that in the event of a hypothetical catastrophic release, ammonia could migrate off the Facility and potentially pose a threat to the surrounding community.  Toxic Endpoint concentrations (TEs) for ammonia published in the EPA regulations were used for this evaluation.  EPA's RMP COMP version 1.06 was used to analyzed the release scenarios.  The 
se scenarios and mitigation measures to limit the migration distance for each scenario are summarized below. 
 
Ammonia Refrigeration Worst Case Scenario - Failure of interconnected portions of the refrigeration systems could cause  the entire contents of both systems to be released over a ten minute period.  Such a release is extremely unlikely since various valves, compressors and other equipment would prevent a release of the entire contents.  However, using the entire contents provides conservative off-site consequence results.  The location of the system inside a buliding was used as a passve mitigation factor.  Modeling results estimate the TE for ammonia could extend downwind as far as 1.2 miles. 
 
Ammonia Refrigeration Alternate Case Scenario - Faiure of a 2-inch transfer hose during ammonia delivery.  Ammonia is delvered to the facility in 2,000 gallon mobile trailers.  Ammonia is off-loaded in an area with a large open delivery door.  Released vapors could migrate off site witho 
ut mitigation from the building enclosure.   It is assumed that the break in the hose is complete and that the operator can close the main shutoff valve in 60 seconds.  Modeling results estimate the TE for ammonia could extend downwind as far as 0.5 miles. 
 
Based on Frozsun's policy, safety meetings for employees are conducted on a continuting basis and ongoing safety improvements are routinely adopted.  Additional employee training and preventative maintenance programs are implemented in response to the results of internal auditing procedures or process changes.
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