Monitor Sugar Company - Executive Summary

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                                                           MONITOR SUGAR COMPANY 
                                                                BAY CITY, MICHIGAN 
 
                                                           Risk Management Program 
                                                                 Executive Summary 
 
 
The Monitor Sugar Company has been in the business of producing refined sugar from sugar beets since 1901.  The company operates one factory located in Bay County, Michigan, one of the largest sugar beet processing factories in the United States.  Additional information about the Monitor Sugar Company and a description of the sugar production process can be found on our website at www.monitorsugar.com. 
 
The employees at Monitor Sugar developed the following Safety Mission Statement: 
 
Monitor Sugar Company is committed to providing every employee with a safe and healthful place in which to work.  Accident elimination is good for everyone because accidents  
produce both social and economic loss.  Only by everyone working together can we achieve an injury free workplace.   
 
Management will provide direction, time, tools, and training regarding safe work practices.  Each employee is accountable for his or her own safety and the safety of co-workers. 
 
A safety team consisting of management and union members provides an avenue for the communication of safety topics/information/issues. 
 
 
Monitor Sugar's Environmental Policy states: 
 
To meet environmental challenges, our activities will support and enhance sound environmental practices.  In managing our business, Monitor Sugar Company will strive to: 
 
( Comply with all environmental laws and regulations. 
 
( Integrate environmental protection considerations into Company planning and decision making. 
 
( Ensure proper handling and disposal of all wastes, and take steps to minimize their generation while seeking opportunities to recycle wastes and use recycled materials. 
 
( Work with appropriate en 
vironmental agencies and organizations to ensure timely, reasonable and cost-effective solutions to environmental issues before they become major problems. 
 
( Participate in the formulation of Federal and State environmental legislation, regulations and policy issues that may significantly impact our business. 
 
( Encourage employee environmental stewardship and ensure a dialogue with management to identify situations in which the Company may improve its practices with regard to environmental laws and regulations. 
 
( Regularly review conformity with this policy to ensure compliance throughout the Company. 
 
 
The regulated substance in use at Monitor Sugar is sulfur dioxide, which is received and stored in 1-ton cylinders.   
 
There was one accidental release of sulfur dioxide in the last five years.  Approximately 1 pound of sulfur dioxide was released.  There was no off-site impact. 
 
Monitor Sugar took data for its offsite consequence analysis for sulfur dioxide from the "Risk Managemen 
t Program Guidance for Wastewater Treatment Plants"  (EPA publication 550-B-98-010).   
 
The worst-case release scenario assumes that the entire content of a single one-ton cylinder is released over a period of 10 minutes.  Such a release would result in an offsite impact. 
 
The likelihood of this type of release is extremely low and Monitor Sugar has not had this type of catastrophic release in its history.  The sulfur dioxide cylinders are safely stored in a designated area, away from high traffic operations.  Employees are trained in the hazards associated with sulfur dioxide and the proper handling of the cylinders.  These procedures reduce the possibility of a cylinder being damaged, resulting in a release. 
 
The alternate release scenario assumes that a small hole develops in a pipe containing sulfur dioxide vapor.  The estimated release rate is 4 pounds per minute for 30 minutes.  This alternate release scenario may result in an offsite release.  While the likelihood of the alterna 
te release is still low, it represents a more realistic cause and size of a release. 
 
Monitor Sugar's Contingency Plan for Hazardous Material would be implemented in the event of an unexpected incident.  Monitor Sugar will work with local and state agencies, if the severity of the incident requires it. 
 
Monitor Sugar strives to reduce the risk of a chemical release by: 
 
( Training employees on the hazards and safe handling of all chemicals used in its operations. 
( Adhering to safe operating procedures in all aspects of its operations. 
( Updating and improving the equipment and processes. 
( Keeping communication open between the company, employees, and the community.
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