TOPS Markets, Inc. NEO 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. Pr 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. SUMMARY OF REGULATED SUBSTANCES The Tops Markets, Inc. located in Maple Heights, Ohio 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. RELEASE SCENARIOS 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: WORST-CASE RELEASE SCENARIO Failure of storage vessels or piping would release 12,250 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 1.3 miles. T here are offsite consequences indicated which affect schools, residences, hospitals, nursing homes, jails, recreation areas, office/commercial/industrial areas, shopping centers, scout camps, and a national/county park. ALTERNATIVE RELEASE SCENARIO The alternative scenario is one of from the 5-year release history. 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 0.1 miles using typical Cleveland meteorology of 3 meters/second wind speed and D stability class. There are offsite consequences predicted affecting residences and commercial/industrial areas. PREVENTION PROGRAM TOPS Market, Inc. has in place a prevention program encompassing elements consistent Occupational Safety and Health Administration (OSHA) Pro cess 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 Markets, Inc. ha s 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 - documentation of tes t 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. FIVE YEAR ACCIDENT HISTORY During the past fiv e years TOPS Markets, Inc. NEO warehouse has had one reportable anhydrous ammonial release. This release did not create an emergency situation outside the plant boundaries nor did it result in any deaths, injuries, nor significant property damage onsite nor known offsite deaths, injuries, evacuations, sheltering in place, property damage nor environmental damage. July 17, 1998: 2,000 pounds of anhydrous ammonia was released to the atmosphere when a process control computer failed. A pressure relief valve opened due to ammonia trapped in a section of piping as a result of the process control computer failing. As a result of the investigation new equipment was installed, new sensors were installed, new process controls and revised operating procedures were implemented. While the above mentioned release had no offsite consequences other than odor, the local emergency responders were notified as required under USEPA CERCLA notification requirements (40 CFR part 302.6). |