Houghton Chemical Plant - Executive Summary

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Executive Summary 
This Risk Management Plan (RMP) was prepared for transfer operations involving Vinyl Acetate Monomer at the Houghton Chemical Corporation located at 52 Cambridge Street in Allston (Boston), MA.  The RMP was developed to fulfill the requirements of the United States Environmental Protection Agency 40 CFR Part 68.  Vinyl Acetate Monomer (VAM) is a new process for Houghton Chemical Corporation. 
Houghton Chemical Corporation is a family-owned and operated distribution and manufacturing company headquartered in Boston with diversified but interrelated operations including but not limited to automotive fluids, heat transfer fluids, water treatment chemicals and industrial chemicals.  For over 70 years Houghton Chemical has built an enviable reputation for high quality and prompt, courteous service in chemicals and chemical-related products marketed on a national and international basis.  Houghton Chemical Corporation is an enthusiastic supporter of many industry and trade  
organizations including NACD, Responsible Distribution Program, ASTM Association of Water Technology, ASHRAE, National Paint & Coatings Association and DCAT.  Houghton Chemical emphasizes safety in the day-to-day operations of the facility.  Employees operate under strict coherence to the Standard Operating Policies for chemical handling and transfer.   
Houghton Chemical's primary business is in the bulk movement of chemicals.  Approximately 20% of the business is dedicated to the mixing and blending of chemicals, including specialty contract blending.  The facility has a flammables permit from the City of Boston for approximately half a million gallons. The chemicals are transported by cargo-tankers and are then unloaded into on site storage tanks and later transfered into individual 55-gallon drums, which are stored in a warehouse at the facility.  Bulk shipments are also transported via the adjacent rail-line.  The most common chemicals handled by Houghton Chemical include methanol, 
acetone, isopropanol, ethylene, glycol and toluene. 
Currently VAM is the only chemical that is stored or manufactured at this facility that exceeds the threshold limits set by the EPA.  VAM is being transferred and stored at this facility in excess of the threshold quantity for toxic chemicals of 15,000 pounds. The process involves the transfer of VAM in a liquid state from a stationary rail car with a maximum capacity of approximately 180,000 pounds to a cargo tanker with a maximum capacity of approximately 40,000 pounds.  Houghton Chemical plans to utilize a vertical aboveground bulk storage tank that is in a diked containment area to store the contents of a rail car at a later date.  When this occurs the transfer will occur between the rail car and the aboveground tank then to a cargo tanker. 
In accordance with the RMP rules for Program 2 a worst-case and alternative worst-case scenario have been developed.  The worst-case scenario is based on the complete release of the largest  
tank which is the rail car storing approximately 180,000 pounds of product.  The resultant plume would have offsite consequences into the greater Boston area.  The alternative release scenario is based on the release of product upon failure of the transfer piping.  The resultant plume would have offsite consequences into a limited area surrounding the facility.  Both scenarios have been analyzed using the RMP Comp program. 
Houghton Chemical has developed a detailed Standard Operating Procedure for VAM handling from tank car to cargo tanker.  The SOP includes a several step process for sampling, quantity verification and transfer processes.  Two employees that are familiar with the product and have donned the appropriate personal protective equipment complete all transfer work involving VAM.  Prior to the actual transfer of product the personnel are required to do a thorough check on all valves, hoses and connections to ensure proper transfer.  During the transfer process personnel are 
constantly monitoring the transfer devices, vapor recovery hose and high level alarms that are connected to the tank receiving the product.  In the event of a release personnel are instructed to immediately initiate the companies Emergency Response Plan which includes notification of the Boston LEPC via a telephone call to 911.  Personnel are also required to take immediate steps to attempt to stop the release while awaiting the appropriate response level for the incident. 
Houghton Chemical Corporation has had no accidental releases of any of the chemical stored at this site over the past five years. 
At this time Houghton Chemical intends to make no changes to the newly developed Standard Operating Procedures for the transfer processes involving VAM.  A dry run was completed prior to the introduction of the chemical to check the SOP and changes will be completed as needed.  Houghton Chemical's dedication to safety and protection of their employees, their neighbors and the environmen 
t will encourage frequent review and updates to the emergency response systems.
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