TOPS Markets, Inc. WNY Warehouse - Executive Summary

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TOPS Markets, Inc. has long demonstrated its committment to health, safety and the environment with its programs and practices that assure a safe workplace, safe quality products for its customers, and environmentally sound processes. 
TOPS' 10-point Health, Safety, and Environmental policy provides a consistent guideline for environmental, health and safety programs, and keeps our commitment to environmental excellence on track.  
Principle I:  
To meet or exceed applicable federal, state and local environmental, health and safety statutes and regulations.  
Principle II:  
To provide a workplace that promotes the health and safety of employees.  
Principle III:  
To the extent reasonably feasible and cost-effective, design facilities and processes to minimize environmental, health and safety impact, consistent with Principle I.  
Principle IV:  
To communicate and maintain an awareness of the commitment to environmental, health and safety protection at all levels of the corporation.  
inciple V:  
To communicate appropriate environmental, health and safety information to affected employees, customers, contractors, members of the public, regulatory authorities and emergency-response authorities.  
Principle VI:  
To support and actively participate in governmental and industry processes, that seek to develop effective, reasonable and balanced environmental, health and safety statutes and regulations.  
Principle VII:  
To utilize natural resources wisely and in a manner consistent with the business needs and goals of the corporation, its customers and shareholders.  
Principle VIII:  
To evaluate environmental, health and safety issues in all significant acquisition and divestiture transactions and facility decommissionings, consistent with good business practices.  
Principle IX:  
To hold all employees accountable for compliance with this policy and  implementing procedures within their areas of responsibility.  
Principle X:  
To establish and maintain corporate control 
s, and to allocate adequate resources, to ensure that the corporation's policy is being properly implemented and maintained. 
The Tops Markets, Inc. located in Lancaster, NY has one regulated  toxic substance covered under Section 112(r) of the Clean Air Act above the Threshold Quantity (TQ) of 10,000 pounds: Anhydrous Ammonia  (CAS No.) 7664-41-7. 
No flammable or explosive chemicals listed in the Accidental Release Prevention  Program exceed the TQ. 
The worst-case release scenario and the alternative release scenario), including administrative controls and mitigation measures to limit the distances for each  reported scenario are outlined herein: 
Failure of storage vessels or piping would release 20,000 pounds of  anhydrous ammonia. It is assumed that the entire contents of the ammonia refrigeration system are released.  
The distance to the endpoint for this worst-case release is 2.6 miles. 
There a 
re offsite consequences indicated which affect schools, residences, jails, recreation areas, office/commercial/industrial areas, shopping centers, the New York Thruway,  parks and a wildlife management area. 
The alternative scenario is one of from the 5-year release history of a sister facility. Equipment failure causes liquid ammonia to be contained in a section of pipe, which then warms and  causes an overpressure situation.  The anhydrous ammonia then is released through the pressure relief valve through the vent  stack.  2,000 pounds of anhydrous ammonia are released in 10 minutes.  Unconfined vapor travels 0.1miles using typical Buffalo, NY,  meteorology of 3 meters/second wind speed and D stability class. 
There are offsite consequences predicted  affecting residences and commercial/industrial areas. 
TOPS Market, Inc. has in place a prevention program encompassing elements consistent Occupational Safety and Health Administratio 
n (OSHA) Process Safety Management Standard(PSM) for Highly Hazardous Chemicals (29 CFR 1910.119).  
The TOPS Market, Inc. warehouse which is covered under the PSM and RMP standards has implemented the following: 
1. An Employee Participation policy has been instituted to  regularly consult with employees regarding the development and implementation of PSM/RMP elements and hazard assessments. 
2. A comprehensive Process Safety Information program which insures complete and accurate written information concerning process chemicals, process technology and process equipment. This information is included in the employee training programs. 
3. Process Hazard Analysis (PHA) is conducted to identify and analyze the potential hazards associated with the processing or handling of highly hazardous chemicals. 
4. The preparation of Operating Procedures that describe tasks to be performed, operating conditions to be maintained, data to be recorded, and safety precautions to be taken. 
5. TOPS Mark 
ets, Inc. has established Employee Training programs to insure that all employees, including maintenance and contractor  employees involved with chemicals, fully understand the potential hazards of anhydrous ammonia.  
6.  Contractors are thoroughly evaluated to insure that they have  the appropriate job skills, knowledge and certifications to perform the job safely. 
7. For any process changes or modifications, a Pre-Startup Safety Review is conducted to insure a safe transition into the normal operating mode. 
8. A Mechanical  Integrity program is in place to assure the  integrity of process equipment. Elements include the following: 
- identification and categorization of equipment and instrumentation 
- inspections and tests 
- establishment of prescribed inspection frequencies, supported by a computer   system for scheduling, reporting, and auditing maintenance procedures 
- development and application of pertinent maintenance procedures 
- training of maintenance personnel 
- document 
ation of test and inspection results 
- documentation of manufacturer's maintenance recommendations 
9. A "Hot Work" Permit system is in place to manage welding, cutting or brazing of equipment in process areas. 
10. To properly manage changes involving ammonia refrigeration, a Management of Change system has been implemented. 
11. In the event of any ammonia release or "near miss" an  Incident Investigation is conducted by a team of experienced individuals familiar with the process. Any recommendations are documented within the Management of Change system. 
12. An Emergency Response program is in place for the entire facility and the surrounding community in the event of an ammonia release. This program is coordinated  with the Cuyahoga County LEPC. 
13. Compliance Audits are performed to review all relevant documentation, verify process safety information, inspect the physical facilities and conduct  interviews with representative plant personnel. 
There h 
ave been no reportable anhydrous ammonia releases in the past 5 years.
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