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The original SPCC plan and all changes must be approved and certified by a Registered Professional Engineer.

In accordance with 40 CFR 112.3 (d), a registered professional engineer has examined the fuel and oil storage facilities and practices at Amherst College, Routes 9 and 116 in the Town of Amherst, Massachusetts, and has determined that all requirements of 40 CFR 112 have been addressed. The SPCC plan shall be modified when necessary by the Amherst College Environmental Health & Safety Manager and will be re-examined and stamped by the registered professional engineer when required.

The above being accurate, I attest that this SPCC/Contingency Plan has been prepared in accordance with good engineering practices.

1. SPCC Plan Purpose: (back to top)
   1. Amherst College is mandated by the federal Environmental Protection Agency (EPA) and Massachusetts Department of Environmental Protection (DEP) to have a Spill Prevention, Control and Countermeasures plan with emergency response/contingency planning activities incorporated there-in to prevent the discharge of all oils including, but not limited to; fuel, hydraulic, transformer and vegetable oil from entering any navigable waters.
   2. The plan must incorporate information like, but is not limited to; facility description and size, number of employees and their training, spill history, hypothetical releases, emergency spill response, inspection methods, plan location and security. In addition, the SPCC plan must  name coordinator(s), primary and secondary as well as identify emergency response agencies that will be called upon to work with Amherst College, both clean up and regulatory. 
   3. The plan has been designed to identify potential environmental risks at the college and to establish a means of effective emergency response to lessen the damage that could occur in the event of a leak, rupture or spills. The following outlines the comprehensive program put together by employees of the Physical Plant.

      As required in 40 CFR 112, Amherst College shall;

   1. have policies and procedures in place to prevent leaks, releases and spills from occurring
   2. inspect, install and maintain control measures to prevent any oil from entering a navigable waterway
   3. have policies and procedures in place to mitigate the negative impact of oil into a navigable waterway

    

2. Definitions: (back to top)

Consumptive Oil - Fuel Oil #6, but predominately #2 used for the purpose if heating.


Department of Environmental Protection (D.E.P.) - The Commonwealth of Massachusetts regulatory agency charged with the promulgation and enforcement of laws pertaining to the environment, including but not limited to air, soil and water.

Emergency Coordinator(s) - a single person, identified by the college who has the authority and resources available to coordinate, delegate, finance, inspect and mitigate an accidental discharge that may adversely affect the college and the environment.  The Emergency Coordinator or his/her designees(s) must be familiar with all applicable campus environmental plans and be able to work in an Incident Command System with the local fire department, LEPC or other regulatory or emergency response agency.

Environmental Protection Agency (E.P.A.) - The regulatory agency charged with the promulgation and enforcement of environmental laws that protect the air, soil, and water at the federal level.

Hazardous Materials - Materials such as chemicals and oil, which if released or misused can pose a threat to the environment and/or health and safety of the community.  Hazardous Materials can be found in agricultural, commercial, industrial, medical and research environments. The materials can be corrosive, flammable, poisonous and/or radioactive.

Hypothetical Release - a worse case situation that may involve the release of oil or other hazardous material into a building or the environment. A hypothetical release must include the cause of a spill or other release, its direction of travel and the impact that it could have on the environment.

Local Emergency Planning Committee (L.E.P.C.) -  A committee set up in each city or town that is responsible for developing an emergency plan for preparing and responding to chemical emergencies (including oil) in that community.

Local Emergency Plan - a document that includes but is not limited to; the identification of local facilities, transportation routes, procedures for immediate clean-up, notification protocols, training exercises and the names of the personnel coordinators and public safety agencies that design, implement, monitor and evaluate the plan.

Material Safety Data Sheets (MSDS) - information made available to employees by the manufacturer of a chemical which outlines the chemical make-up of the material, its hazards, proper personnel protective equipment, proper use, first aid and emergency response actions and other applicable health and safety communications.

Municipal Coordinator - An official, generally the Fire Chief, Health Commissioner, Public Health Officer or their designee appointed by the Town Administrator or Select Board to oversee the Local Emergency Planning Commission and applicable Community Right- to- Know plans for the town or city. For the Town of Amherst - Michael Zlogar - Assistant Fire Chief.

Navigable Waters of the United States are those waters and contributories that contain water of a period of at least one month over the course of a year and permit the relocation of possible contaminates such as oil to a brook, stream, river or lake.

Oil - any type or form of oil, including but not limited to fuel oils (#2 and #6), motor oils, hydraulic and transmission fluids, transformer oil, synthetic oils, vegetable oils and grease that include canola, peanut and sesame seed and vacuum pump/compressor oils, as well as the associated wastes.

Oil filled Equipment - include, but are not limited to hydraulic systems such as elevator and lifts, lubricating equipment for pumps, compressors and other lubricating systems, gear boxes, machine coolant systems, heat transfer systems, transformers, switcher containing oil and other systems that contain oil solely to enable the operation of a device.

Reportable Quantity - is the amount of material, when spilled or otherwise discharged into the environment, that dictates when a facility must notify the local regulatory agency, the Department of Environmental Protection. For the purposes of this plan, most oils have a reportable quantity of greater than or equal to 10 gallons.

Response Action – any action such as assessment, containment, removal, disposal, treatment or storage undertaken as part of a corrective action performed pursuant to MGL c. 21E and 310 CMR 40.000, Federal Superfund (CERCLA), RCRA corrective action or an analogous clean-up authority within another state.

Tank- a container specifically designed and in some cases permitted to contain gasoline or oil for the purpose of fueling and heating.


• Aboveground Tank(s) are tanks that have not been buried beneath the ground by means of earth covering.  Above ground tanks shall include those tanks that have been placed in the basements of faculty houses, dormitories and other similar locations.
  
  
• Underground Tank(s) are tanks that have been buried beneath the ground. These do not include those tanks that have been placed in the basements of residences and other housing even though their physical placement is below grade. 


Threat of Release – means a substantial likelihood of a release which requires action to prevent or mitigate damage to the environment which may result from such a release. Circumstances that represent a threat of release include, but are not limited to, sites or vessels containing or conducting an amount of hazardous waste in excess of the reportable quantity for that hazardous waste where  no release has occurred but where corrosion, damage, malfunction or other conditions are visible, known to exist or should be known to exist and where these conditions are likely to result in a release.

3. Scope: (back to top)
   

In accordance with the requirements of the Environmental Protection Agency and more specially SARA Title III, Amherst College has developed and implemented this Spill Prevention Control and Countermeasures Plan or (SPCC) to prevent and when necessary control oil discharges, leaks and spills into the environment as outlined in the Clean Water Act (CWA).

Under this plan, Amherst College must identify all oil containment, storage practices, monitoring, use and transportation applications and then develop a response action in case of leaks or spills.  The college must also provide training for all applicable personnel.  There must be written standard operating guidelines, actual drills, exercises and meetings.

    Amherst College shall review this SPCC plan...


• at least every 5 years
• when a more effective prevention and control technology has been developed
• when significant changes in the facilities design, construction, operation or maintenance has taken place


=> Amendments and changes to the Amherst College Spill Prevention Control and Countermeasures Plan shall be approved and certified by a registered professional engineer.

4. Applicability (back to top)
   1. Amherst College is required to prepare and maintain and SPCC for the following reasons;
      1. we are non-transportation related on shore facility
      2. our total above ground oil storage, including those tanks used for home heating located in the basements of dormitories and faculty/staff housing exceeds 1,320 gallons, with underground capacity of both #2 and #6 fuel oil at 60,000 gallons, which meet the requirements of 40 CFR part 280 and 281.
      3. the location of the college can be reasonably expected to discharge oil into a brook, creek, conservation area, pond, river, ocean or other navigable waters of the United States or adjoining shorelines.  Areas of concern might include;
         1. Fearing Brook, East of Hills Parking Lot
         2. Fort River, South of the campus
         3. Hadley Reservoir, North of the Bunker
         4. Harts Brook, West of University Drive
         5. Conservation Area, South of Amherst Farmers Supply
      4. Amherst College in its entirety meets the requirements for a commercial, agricultural or public facility that uses or stores oil
         1. The Physical Plant at Amherst College is responsible for a containment, maintenance, storage and use of consumptive fuel oil in all dormitories, houses, and academic facilities on campus and under the control of the Board of Trustees and the President of Amherst College.
            
            
5. Responsibility (back to top)
   

Amherst College Emergency Number (24/7) ........... (413)542-2111

The Spill Prevention, Control and Countermeasures Plan (SPCC) shall be under the control of the Emergency Coordinator/SPCC Coordinator;

Jim Brassord, P.E.
Director of Facilities Management & Planning
Physical Plant
6 East Drive
Amherst College
Amherst, Ma 01002-5000
Telephone : (413) 542-2202 (work)
                     (413) 549-3803 (home)
                     (413) 542-2291 (emergency)


If the above referenced Amherst College Emergency Coordinator/SPCC Coordinator is unavailable, the following person(s) shall make themselves available for inspection and emergency response;

Richard A. Mears Environmental Health & Safety Manager Physical Plant 6 East Drive Amherst College Amherst, MA 01002-5000 (413) 542-8189 (work) (413) 542-2254 (work) (413) 549-0898 (home) (413) 263-7894 (pager) (413) 530-8782 (cell)

Aaron Hayden Campus Systems Utilities Engineer Physical Plant 6 East Drive Amherst College Amherst, MA 01002-5000 (413) 542-2644 (work) (413) 542-2254 (work) (413) 256-8260 (home) (413) 530-3678 (cell)

General

Amherst College, as required in our SPCC plan has, to the best of our knowledge met the requirements of 40 CFR 112, as a Tier III facility which include the following provisions;

Facility layout - locations and control measures for all oil related equipment and storage, the location of our sanitary and storm water systems and detention/retention ponds, stormwater management controls and appropriate site security and emergency/non-emergency notification procedures.

Facility Inspections - depending on the hazard, location of hazard and control measures in place, which include monitoring systems, double wall tanks and secondary containments, Amherst College perform inspections at least annually, if not monthly, weekly or daily on all systems that contain or distribute oil.

The SPCC plan has managerial/administrative support from the President of the College and the administration. The SPCC plan is reviewed and amended every 5 years, or more frequently as needed and is signed by a registered professional engineer familiar with and approved for SPCC plans.

1. In accordance with our regulatory requirements, Amherst College must report all leaks, ruptures, spills and other discharges of "reportable quantity" to the local fire department and other applicable regulatory agencies including but not limited to the State of Massachusetts Department of Environmental Protection and the National Response Center.
2. The Amherst College SPCC Coordinator or his/her designee shall be responsible for all appropriate notifications.
   • The notifications (when possible) should be made through the Amherst College Police Dispatch Center so that an audible record of the incident with dates and times can be maintained.
   • The SPCC Coordinator or their designee shall be part of the Incident Command System (ICS).  They shall meet with and assist the local fire department, the Department of Environmental Protection and any other appropriate agency with the needed resources to help control any additional or potential negative environmental impact.
     

The SPCC Coordinator shall be responsible for equipment, material and monetary resources to aid in the hazard mitigation.

1. The SPCC Coordinator is required to oversee and maintain the SPCC Plan. As part of this plan, he/she shall...
   • keep the plan up to date
   • reviews and appropriate changes must take place...
   • when a release has occurred
   1. whenever the operation of the facility or its storage, use or transportation of oil is altered
   2. when a more effective prevention and control technology has been developed and recommended, or at least every (5) years
   • provide all necessary training to staff, both emergency response personnel and the general workforce.  Personnel identified as emergency response of the general workforce must be able to recognize and properly respond to a problem or potential problem that involves the materials (i.e. oil) discussed here-in.
     
     

Amherst College is a four-year liberal arts college that is located in the center of the Town of Amherst, Massachusetts, in Hampshire County at the intersections of Route 9 and 116. The elevation at the highest point is Johnson Chapel at 11 Quadrangle Dr, which is located [(42º 22'  14.99N ) (72º 31'  05.06W )]. The college has approximately 180 buildings on site, including academic facilities, dormitories and private residences which are rented or owned by college faculty and staff. The buildings on campus are maintained by the Physical Plant, which is located at 6 East Drive, off College Street immediately across the intersection from Dickinson Street and Amherst Rental Properties at 212 Northampton Road in Amherst.

The facilities for which this plan was prepared include; the Hazardous Waste Storage Facility, the Old Power Plant and Physical Plant Garage on East Amherst College Drive, the Power Plant on College Street, the Lord Jeffery Inn at the corner of Spring Street and Boltwood Avenue, the Amherst Golf Club at 365 South Pleasant St., The Amherst College Book Depository, 100 Military Road, adjacent to the Notch Visitors Center and residential occupancies which include dormitories, single and multiple family homes.

Amherst College has two (2) newly installed (July 2001) 30,000-gallon underground storage tanks located just to the north of the Power Plant at 151 College Street. These tanks contain #2 and #6 fuel oil (very viscous, slow moving oil) used for the purpose of heating. In addition, the college has one other underground fuel oil storage tank that was recently replaced in 1998 with monitoring devices and double wall containment. It is located on the North side of the Lord Jeffery Inn at the corner of Boltwood Avenue and Spring Street. The tank contains 3,000 gallons of #2 oil for heating. The Amherst College Book Depository has two (2) exterior, double wall (monitored) tanks. One located beneath the emergency generator (340 gallons) and the other for heating oil (3,000 gallons). Both of the tanks are located North of the building, at the front entrance.

Most of Amherst College sits on a hill that peaks at Johnson Chapel at 11 Quadrangle Dr, North of 220 South Pleasant St (Route 116). At this point [(42º 22'  14.99N ) (72º 31'  05.06W )], Amherst College is 331 feet above sea level. Water and other material have the potential to flow down hill in all four directions from this point. From past experience the college has identified (4) potential waterways that have or could be affected by an accidental discharge. They are;

1. Fearing Brook to the north and east which runs parallel to the railroad tracks at 151 College Street.
2. Harts Brook in Hadley to the west, which could take a leak or spill from South Prospect St and points west. The Fort River or the conservation area to the south of the campus which are contributors to the Connecticut River.  
3. Hadley Reservoir, which is North of the 5 College Book Depository at 100 Military Rd.

Most of the academic and residential buildings that are located at the core of the campus are heated by steam, which is generated by the Power Plant. Oil in these buildings is limited to emergency generators, transformers, switches compressors, pumps and hydraulic elevators. Some residence halls however, which are located on the outer perimeter of the campus, north of College Street and west of South Pleasant Street (Route 116) have oil burners which are normally fueled by #2 fuel oil, (3) 330 gallon tanks, just under 1,000 gallons in each of the 7 buildings.

In addition to the 83 academic and dormitory buildings on campus, Amherst College also has 105 residential homes that are either rented or have been purchased by a member of the faculty or staff. Many of these private residences have consumptive fuel oil for the purpose of heating. Although none of these homes have underground storage tanks there is still a potential to have oil contamination in or around the property that could make its way into the environment because of tank overflow, leak or rupture.

In an effort to prevent future oil spills and environmental damage Amherst College has removed all of the underground storage tanks from the dormitories, single and multiple family residences and replaced them with either; above ground oil storage tanks, which have been placed in the basements or have converted the dormitories or homes over to gas, natural or propane. All new or existing oil tanks are being inspected at least annually by our outside oil burner contractor, Amherst Rental Housing and Environmental Health and  Safety for leakage and general overall conditions. If deterioration, a leak, rupture or spill occurs, the contractor or Amherst College employee who discovers the deficiency will report it to the Physical Plant or Amherst Rental Housing, who will then take the necessary corrective actions to insure minimal damage or discharge. Their findings, corrective actions or plans shall be reported to the Assistant Director of Operations and/or the Environmental Health & Safety Manager, as soon as possible.

Amherst College Book Depository

The Amherst College Book Depository (aka Bunker) is a former military bunker that is located off campus at the Notch on Route 116, just north of the Granby/South Hadley town lines. The address is listed as 100 Military Road which is on the right side of route 116, one mile past Atkins Fruit Bowl, located at the intersection of Bay Road and Route 116 in Amherst. The Amherst College Book Depository, home of the 5-College Book Depository has an emergency generator on site, just north of the main, front entrance. This generator has its own fuel storage tank which is located to the South of the exterior mechanical room. The total quantity for the tank is 340 gallons. In the event of a complete tank failure, the diesel fuel will run on to the ground or into the adjoining parking lot that does not have storm or sanitary sewer drains. Spill containment and cleanup should be fairly easy, because the diesel fuel (unless it rains) has no place to go. The closest waterway is a brook or stream ¼ mile downhill that flows into the Hadley Reservoir which is north of the facility.

The emergency generator is tested weekly by the Physical Plant Electric Shop or Cummins North East Generator Service, so any deficiencies involving the tank or generator will be reported, immediately. Additionally, because the tank is above ground, near the main entrance, it will be monitored daily by the Book Depository Staff who can and have reported concerns to the Physical Plant. In addition to the diesel fuel tank for the emergency generator, the Amherst College Book Depository also has a 3,000 gallon fuel oil AST for heating. This tank, like the one for the emergency generator is located on the North side of the building at the main entrance. This tank, as required by regulatory requirements is a new (1999) double walled tank with a monitoring device that alarms if product enters into the secondary containment.



Power Plant

The Amherst College Power Plant is located at 151 College Street, just east of the railroad tracks from the Physical Plant Service Building and across from the entrance to Railroad Street in Amherst.

The largest potential problem at the Heating Plant is the (2) 30,000 gallon underground storage tanks that are used to store #2 and #6 fuel oil. The #6 heating oil consumed at this location is pumped from the in-service tank to a heat exchanger where the fuel temperature is increased to provide the proper viscosity for the fuel to be burned. The amount of fuel pumped to the burner in excess of that required to maintain the campus steam load is re-circulated back to the in-service tank. Piping is configured such that either tank can be lined up as the service tank. The #6 tank is used throughout the heating season and uses (1% sulfurated oil) and can be shifted to #2 oil or gas at any time by power plant personnel.



1. #6 Oil Tank Monitoring System
   
   System Description:  The tank monitoring and leak detection system consists of the following components manufactured by Pneumercator Company, Inc.
   

    

   LDE 740 Console with Printer

   Two 2-501 Level Transmitters

   Five LS 600-LD Leak sensors

   LC1002 Overfill Alarm Console

   
   Level Transmitters: The 2-501 Level Transmitters are installed in the center manhole of each tank.  The transmitter contains a float that measures the level of the product.  The transmitters are factor calibrated and "zeroed" to actual product levels in the field.  No water or temperature readings are available.  Parameters (low level, overfill, etc.) are programmed at the console.
   
   Overfill Alarm: The Overfill Alarm console is mounted on the exterior wall of the Power Plant.  The console includes a test button to test the console circuitry and a reset button to acknowledge an alarm.  It also includes a light for each tank to show an overfill condition.  The console if controlled by a programmable relay in the LDE 740 Console.  This device is the overfill prevention measure required by Federal and State regulations.  It is programmed to alarm at 90% of the tank capacity.
   
   Leak Sensors: There are five float-type leak sensors installed.  These are non-discriminating sensors.  All alarms should be immediately investigated to determine if the sensor is in water or fuel.  The sensors will also alarm if defective or if the wiring is shorted.  These sensors can be manually tested by immersing water or turning upside down.  It is recommended that they be manually tested annually.  Sensor description is listed on the inside of the console as follows:
   

    

   S1: Tank 1 Interstitial Space 

   S2: Tank 1 Cofferdam 

   S3: Tank 2 Interstitial Space 

   S4: Tank 2 Cofferdam 

   S5: Piping Vault at Building 

    

   
   Maintenance and Testing of #6 Fuel Oil Tanks
   The following procedures have been integrated into the Power Plant's maintenance procedures.
   
   Daily:
   

   Verify operation of console LED display and that the active tank is selected 

   Ensure that the inlet oil temperature does not exceed 130 degrees F. Adjust tank coil or preheat to reduce temperature.  Excess tank temperatures will lead to premature tank failure due to formation of Sulfuric Acid. 

    

   
   Before Each Delivery:

   Verify tank capacity.  Press “Print” on the console door.  Subtract 3000 from the column labeled “ULAGE”.  If the result is equal to or greater than the truck contents, you have room for safe delivery. 

   Test the overfill alarm by pressing the “TEST” button.  The tank lights should illuminate and the horn sound. 

   Open the Cofferdam door on the tank to receive the delivery and inspect. 

   Remove any fuel or water from the spill containment manholes.

   
   

    

    

   
   Monthly
   First Monday of Each Month:

   Inspect spill containment manholes, cofferdams and piping vault.  Note any unusual conditions or the presence of water or fuel. 

   Manually gauge the tanks. Compare readings with the console. 

   Manually trip each sensor and verify alarms 

   Manually gauge each tank and compare reading with console display.  Adjust as necessary. 

   Manually test the Overfill Alarm by reprogramming the High Alarm Limit. Instructions for entering the High Alarm Limit  are found on page 34 of the manual.  For example, if Tank 1 contains 21, 375 gallons, reprogram the limit by pressing F09121000E. After verifying the operation of the alarm, return the setting to the 90% setting. 

   Open the steam control valve of bypass to the tank coils a minimum of 24 hours before attempting to start the pumps.  Ensure that the valves in the cofferdam are open on the active tank. 

   
   

    

    

   
   Fuel is delivered to the tanks by tanker trucks (approximately 8,000 gallon capacity). The truck driver places the truck on the driveway adjacent to the tanks and within hose length of the fill pipes. The driver then checks in with the boiler room staff.  After recording the tank volume in a logbook, the plant staff assists the driver in connecting the tanker hose to the fill pipe.
   
   Power Plant staff stand-by while pumping commences and checks tank vent pipes for escaping air. The driver remains by his/her truck during the entire pumping process. When the delivery has been completed, the driver secures the truck and the fill station and departs the campus.
   
   On the East side of the Power Plant, North of the stack, is the Emergency Generator, which contains 330 gallons of diesel fuel.
   

    

   Weekly inspections of the generator are performed

   
   Additional oil products, treatments and other hazardous materials (primarily boiler water treatment chemicals) are stored in (55) gallon drums, located NW of the Power Plant Office. These chemicals are set in or on secondary containment to prevent accidental discharge into the sanitary sewer.
   
   The oil/water separator on the North side of the Power Plant is a 400-gallon tank that is responsible for collecting water (if any) that accumulates on the floor of the Power Plant, before it discharges to the sanitary sewer.
   

    

   The tank is pumped out annually or as needed, at the request of the Power Plant Supervisor, by Triumvirate Environmental Inc.
   
   

2. Physical Plant Garage, 2 East Dr.



The Physical Plant Garage is the location of a 500 gallon underground oil / water separator at the Northeast corner of the building. The oil/water separator is connected by piping to the floor drain in the center of the garage. Oil that enters the system via the floor drain is collected in the trap, allowing only water to continue on into the sanitary sewer.  In May 2002 the four-year-old 2,000-gallon underground gasoline tank was removed for the installation of new utilities (electrical).  In its place Amherst College installed a 1,000 gallon above ground gasoline tank with vapor recovery system, which is now located at 100 East Dr, which intersects with South Amherst College Dr.  The former UST located at 2 East Dr. was registered with the Commonwealth of Massachusetts as site #168.  All paperwork has been submitted to the Department of Revenue, including the FP-209 Form. The tank has been officially removed from service.

The Physical Plant Garage is a small (2) bay facility with a single lift that is used for the maintenance and repair of Amherst College vehicles. The wastes oils and clean up rags are stored in small containers in the garage for a limited period of time. When these containers are filled, they are emptied into the provided hazardous waste containers located in Bay 4 of the Hazardous / Universal Waste Storage facility located to the north of the garage. The garage also has a 9,000 lb. Rotary Lift with less than 10 gallons of hydraulic fluid in the system. In case of failure, such as a leak or rupture the hydraulic fluid would end up on the floor where it would be cleaned up. Under a worse case scenario it would end up in the floor drain which is protected by the oil trap. Batteries and antifreeze are also found in the garage for a limited period of time. They are frequently relocated to the storage facility because of better containment and the lack of space within the garage. Hazardous Materials such as spray paints, lubricants and oils are placed in Flammable Storage Cabinets for reasons of fire safety



1. This facility is inspected daily by the maintenance supervisor and periodically by the Environmental Health and Safety Manager.

2. Hazardous / Universal Waste Storage Facility
   
   The Hazardous / Universal Waste Storage building is located on the north side of the garage at 2 East Drive. The building is a 4 Bay (26,000 lb.) storage facility specifically designed for the storage of hazardous materials and waste.
   
   Each bay is a separated from the others by a full fire rated metal wall. The individual bays have there own entry points and overflow containment, under the grated floor.
   
   

   Bay 1 (East most bay) is used for the storage of spill containment equipment and materials including pads, pillows, poly bags, 5 gallon DOT approved poly-pails, speedi-dry and a variety of other similar material. 

   Bay 2 is used for the storage of empty drums and fiberboard containers.

   Bay 3 is used for the storage of Universal Waste (batteries) ballast’s and old batteries from the garage. Very infrequently there may be a container of a corrosive liquid awaiting proper disposal through our hazardous waste contractor, because it is incompatible with the contents of Bay 4. 

   Bay 4 is used for the storage of combustible waste (paints, oils and cleaners). It is very rare to find waste in excess of 200 gallons. Waste oils are composited on occasion in Bay 4 and then properly disposed of via our hazardous waste hauler. 

   
   The Environmental Health and Safety Manager inspect all of the bays at least weekly. A copy of the inspection reports can be found in Bay 4 for the last month with records prior to that in the EH&S office. They are updated every Tuesday, during the inspection. Deficiencies are addressed immediately. The inspections are performed by the EH&S Manager or in his/her absence by the Director of Operations.
   If a spill were to occur at this site, it would easily be contained in the provided sumps at the base of each bay, under the metal grates. The doors to each bay are properly labeled to identify the storage within.

Universal Waste Facility

1. The Universal Waste Facility used for the temporary (≤ 365 days) is located in the garage behind 62 Snell St. At that location, cardboard, old fluorescent lights and other universal waste are kept until removed by a Universal Waste Contractor.
2. Old Power Plant

   The Old Power Plant located at 10 East Drive is now the home of the Grounds Department. Outside the Building on the Southeast corner of the building is a 3,000 gallon diesel fuel tank used for the refueling of the diesel trucks, tractors and pay-loaders used on campus, which was installed in 2007.
   
   The newly installed 3000 gallon tank has secondary containment, overflow protection, a new pump, a fueling pad and appropriately placed bullards to protect against vehicle damage. The new tank replaced an older single wall 500 gallon tank that was not equipped with secondary containment or alarms, and then a 1,000 gallon tank that was determined to be too small for fueling frequency. The building, because of its large doors is used for the storage of equipment, including a large payloader. Diesel fuel and hydraulic fluid have the potential to leak out of the loader, run along the floor and possibly into the floor drain or down the stairs to the floor drain in the basement. This however is very unlikely because of floor pitch, quantity of fuel on the loader and daily inspections of the room and equipment. If the larger than normal spill was able to enter the floor drain, it  would most likely end up in Fearing Brook, which empties into the Fort River.
   
   Other items stored in the Old Power Plant include; oils (gear, lubricating and motor), pesticides in limited sizes and quantities, gasoline in portable tanks and other similar material.
   
   

   Lord Jeffery Inn
   
   The Lord Jeffery Inn is located on the corners of Boltwood Avenue and Spring Street in Amherst. Amherst College owns the building, but Pinacco Hospitality leases the facility. The “Lord Jeff” has a restaurant, and sleeping accommodations. The 3,000 gallon double wall, monitored #2 fuel oil tank is used for the purpose of heating. The tank is located underground on the north side of the building, just to the east of the entry door.
   
   If a spill were to occur, the direction of flow would most likely be east, toward the Fearing Brook, which empties into the Fort River. If overflow during filling were to occur, it would end up in the storm drains along Spring Street and then eventually find its way to the Fearing Brook.
   
   

   Amherst Country Club
   
   Amherst College owns the Amherst Country Club. The golf course recently went through a tank removal / replacement program that resulted in the replacement of an underground storage tank with a new above ground vaulted tank. Both new tanks are 500 gallon in size and are located on the south side of the maintenance shop. The (2) tanks, inside a concrete enclosure contain gasoline on one side and diesel on the other. In addition to the exterior tanks referenced above, the golf course maintenance garage also has a satellite accumulation area for waste motor oil. The container is 55 gallons in size and sits upon a sump pallet, as does the storage of new product.  In May of 2002, a vapor recovery system was installed. Training, documentation and record keeping are all on file at the Physical Plant.
   
   Spills at this site will most likely end up in the Fort River via the conservation area directly across the street. However, the possibility of discharge, leak, rupture or spill is very improbable because of the new tanks and associated containment system.
   
   

   Valentine Dining Hall
   
   The single, 175 table dining hall at Amherst College is Valentine. It is located at 59 College Street on the north side of the campus core. Meals are served three times a day utilizing a wide range of equipment including grills, fryolators, pot washers, garbage disposals and sinks which all have the potential to contain grease.
   
   The largest quantity of fuel grade oil at this site is located in room 002, just east of the loading dock. Inside this area known as the dry storage room there could be up to 76 gallons of oil. These include:
   

Extra Virgin Oil 12 gallons
Sesame Oil  12 gallons
Corn Oil  12 gallons
Peanut Oil    4 gallons
Canola Oil  20 gallons
Salad Oil  16 gallons


The room has two (2) floor drains which have been plugged to prevent accidental discharge into the sanitary sewer system.


The other area used for the storage of oil is the walk-in cooler to the south of the loading dock in room 001. In this refrigerator there is a 55 gallon drum of waste vegetable oil (solid). The grease from the fryolators is placed in this container temporarily until such time as an outside vendor removes it. The solid waste in the 55 gallon container located in the walk-in refrigerator (to prevent liquefaction) is labeled waste grease or waste vegetable oil. The container is placed upon a plastic skid to prevent accidental personal injury and spillage. In addition, a second 55 gallon container was installed for the proper disposal of waste vegetable oil with filter papers and wipes. The second waste container is removed by out hazardous waste contractor and not the Western Mass. Rendering Service.

Located on the North side of the dining facility is a 1,500 gallon grease trap that was designed to separate the water from the grease and vegetable oil that enters the system. The sinks located on the lowest level of Valentine (known as the pot sinks) empty into the grease trap noted here-in.

The grease from this trap separation system is extracted at least twice annually. 



Tennis Barn, 100 East Dr.

In May 2002, Amherst College installed a 1,000 gallon AST for the storage and use of gasoline to fill lawn mowers, tractors and other similar equipment.  This tank is double walled steel with all of the appropriate equipment as required by 527 CMR 9 and approved by UL. The tank is equipped with Stage I Vapor Recovery, and all documentation and training has been completed.  Copies of both are available upon request.



Residential Housing

Amherst College has approximately 100 residential occupancies including apartments, dormitories and rental properties for faculty and senior administrative staff. Most of these buildings are heated with #2 fuel oil. The tanks, which range in quantity from a single 275-gallon for houses up to (3) 330-gallon capacity tanks for dormitories are located in the basements.

The tanks are inspected unofficially by the owner/renter of the property who reports any problems to Amherst Rental Housing. In addition, the heating systems in the houses are serviced annually by a contracted, authorized service technician, and are inspected by the Amherst Rental Housing or Environmental Health and Safety as part of a yearly site evaluation process. The oil tanks have been incorporated into our TMA Work Order System and are flagged for purposes of yearly inspection.

Beginning in 2005, Amherst College has initiated a program to replace oil tanks in houses or other residential occupancies that have floors with cracks, holes or other similar deficiencies that could permit the spread of oil. Amherst college is replacing older oil tanks with double wall, bladdered, stainless steel Roth Tanks.

Underground Storage Tanks
- Leaks, Overflows, Ruptures or Spills

The underground tank for the Lord Jeffery Inn was replaced with a double wall tank and monitoring devices to detect leaks in 1998. For this reason it would seem that the only possible means of accidental release into the environment would be by human error or mechanical failure, overfilling the tank, improper use of off-loading equipment by the operator of the tanker truck or defective equipment such as a damaged hose.

• In this case oil from the tank referenced above would end up via storm drain in the Fearing Brook, which runs along Spring Street towards Railroad Street and across College Street, ending up in Fort River.

In 2001 (2) 30,000-gallon underground tanks for the storage of #2 and #6 fuel oil were installed at the Power Plant. The tanks are continuously  monitored and the facility is staffed 24 hours a day, 365 days a year. Although it may be possible for the tank or tanks to fail, the likelihood is remote. Human error or mechanical failure would be the most likely cause an unwanted discharge. If this were to happen, the #6 fuel oil would move slowly down the hill /parking lot towards the Fearing Brook, located behind or east of the Heat Plant. 

• Monitoring wells for these tanks were installed in – Summer 1999.  They were left in place after the 26 year old tanks were removed in - Summer 2001 See Spill History Log for August 1999 (Page 26, item #12)

An underground oil separator is located outside the Power Plant and Physical Plant on the Northeast corner of the garage. If the separater were to become clogged and have a release, oil from the garage floor drain might end up in the sanitary sewer, but would not enter into the environment via storm drains or run-off.



Above Ground Storage Tanks and Containers
- Leaks, Overflows, Ruptures and Spills

Oil tanks in quantities ranging from 275 gallon to (3) 330 gallon tanks are located across the campus in dormitories and in homes owned by the college, single and multi-family. Most of these tanks are located in the basement of the houses, which in some cases have old floor drains beneath grade. For this reason, a leak, rupture or spill from a tank could end up in the drain, which could lead directly to the exterior of the building, then into a waterway via a storm drain or groundwater. Another possibility would be human error or mechanical failure that could create the same negative environmental impact. 

Drums 30 and 55 gallon used for the storage or transportation of oils and non-flammable hazardous materials are located in the Hazardous / Universal Waste Storage Facility, the Physical Plant Garage and the Amherst College Heat Plant. These drums can be damaged during shipping, dropped by staff from the college or punctured by other means. Each bay within the building has its own spill containment which is inspected at least weekly by Environmental Health & Safety. 

Elevators, switches, transformers and other equipment have reservoirs for the storage of oil, hydraulic fluid etc. Mechanical failure at joints or human error at times of installation or replacement may create an unwanted accidental release.

June 12, 1988- Amherst College experienced a spill at a faculty member's home from an underground oil tank at the Lovin's House, 157 Mill Lane.  The spill of more than 250 gallons was reported to the Department of Environmental Protection, (formerly the Department of Environmental Quality Engineering) at 06:30 a.m.


The project was closed out on July 26, 1988


W88-0284 (DEP Tracking Number)



June 25, 1991- Amherst College experienced a spill at a faculty member's home.  Waste oil of an unspecified amount was discovered at Cowles House, 96 Northampton Road.  The spill was reported to the Department of Environmental Protection (DEP) at 03:25 p.m. on the same day.


The project was closed out on November 01, 1991


W91-0359 (DEP Tracking Number)

July 27, 1993 – Amherst College experienced a spill at Seelye Dormitory, 129 South Pleasant St. Oil of an unspecified amount was discovered and reported to the DEP at 0:35 a.m. on the same day. It is believed that the contaminated soil found at the fill pipe was the result of many years of improper delivery practices in which oil was spilled onto the ground during regular fuel supply.


The project was closed out on July 30, 1993.


W93-0401 (DEP Tracking Number)

December 06, 1993 – Amherst College experienced a large spill from an underground storage tank at the Alumni House, 75 Churchill St. The spill that was initially discovered as an oil sheen on Fearing Brook, east of the building was traced to the 1,000 gallon underground fuel oil storage tank at the Alumni House. The spill was reported to the DEP by the Amherst Fire Department on the above referenced date at 12:00 p.m.. At the time of discovery, Amherst College placed absorbent booms at the culvert access and in the storm drains, east of the site. The offending tank was removed on December 08, 1993 and more absorbent pads were placed at the bottom of the excavation, which had  standing water and petroleum. Approximately 160 yards of soil was removed from the site. Post excavation composite samples were collected from the floor and walls and submitted for Total Petroleum Hydrocarbons (TPH) analysis by EPA method 418.1. On June 27, 1994 (3) 2” diameter groundwater monitoring wells were installed at the site. On July 05, 1994 an additional TPH was performed following EPA methods 418.1 and 624. A report was prepared by Contest Environmental Consulting-Testing, which is on file at Amherst College, Engineering Department. Project Number 94-210-426.


The project was closed out on October 6, 1995.


1-10103 (DEP Tracking Number)

March 08, 1994 – A #2 fuel oil spill of approximately 15 gallons occurred at 19 Hitchcock Street, adjacent to Amherst College property. The spill took place at a private residence and was caused by a deficiency involving a pipe at that site. The spill was reported to the DEP within 2 hours of the incident.


The project was closed out on April 5, 1994.


1-0010231 (DEP Tracking Number)

April 12, 1994 – While in the process of voluntarily removing an underground storage tank at 22 Hitchcock St., the Babbott House, Amherst College personnel discovered that the tank had been damaged and was leaking #2 fuel oil into the trench.


The project was closed out on April 15, 1999.


1-0010292 (DEP Tracking Number)


August 08, 1994 – The DEP has identified a spill of #2 fuel oil involving Amherst College. The spill, which was reported by David Lauder, Mechanical Shop, occurred at 82  Lessey Street, the Plimpton House.  It was reported as a spill of 10 gallons of #2 fuel oil. 


The project was closed out on September 29, 1994.


1-0010489 (DEP Tracking Number) 

January 23, 1996 – A spill of approximately 60 gallons of #2 fuel oil is reported to the DEP. The location is the Lord Jeffery Inn, which is located at 30 Boltwood Avenue and the corner of Spring Street. The spill originated at the pipe of the underground storage tank and the incident was reported within 2 hours of the initial discovery.


The project was closed out on March 22, 1996.


1-0011214 (DEP Tracking Number) 

May 01, 1997 – While in the process of voluntarily removing an underground storage tank at 22 Snell Street, the Morgan-Ponty House at Amherst College, the tank removal contractor noticed a damaged tank that had been leaking into the trench. The #2 fuel oil spill was reported to the DEP within 2 hours of discovery and involved approximately 10 gallons of oil and at least 60 cubic yards of contaminated soil.


The project was closed out on July 07, 1997.


1-0011802 (DEP Tracking Number) 

October 30, 1997 – Lapinski Electric Inc., was lifting a new transformer off the back of a delivery truck during a construction project, the cable/strap used for picking up the transformer broke causing the transformer to strike the ground inflicting damage in the form of a small crack. The oil (non-PCB) began to leave its containment, dumping out onto the ground. Quick response by members of the Physical Plant, Lapinski Electric Co. and others minimized the damage to the environment. The spill was contained to the pavement at Alumni Gym and the rest of the transformer was drained before it became completely empty.


The project was closed out on January 5, 1998.


1-0012073 (DEP Tracking Number) 

March 15, 1998 – Although it turned out not to belong to Amherst College, Physical Plant staff was requested by the Amherst Fire Department to assist in the investigation of an odor of oil on South Pleasant Street in Amherst. While checking on the odor, sheen was discovered in the brook by the bike path leading to the bird sanctuary, south of Amherst College. The odor and sheen was traced back to 53 South Prospect Street, Marshal Steinbeck’s garage where a 250 gallon above ground, exterior oil storage tank was found to be leaking into an open catch basin on the northwest corner of the garage. At that point, the owners of the property, D.H. Jones Realty were requested. Amherst Fire Department and Amherst College assisted with spill containment and clean-up operations for over (2) hours. The site was turned over the DEP for further corrective action. Southampton Engineering was called in to aid in the clean-up process, but the bulk of the clean-up activities had already been accomplished the day before.


The project was closed out on August 21, 1998.


1-0012236 (DEP Tracking Number) 

August 1999 - Amherst College contracted ATC Environmental to install Monitoring Wells around our (2) 50,000 gallon #6 fuel oil tanks. Amherst College opted to utilize this particular technology at the suggestion of Don Grant (EPA SPCC Coordinator) who we spoke to at an April 27, 1999 roundtable put on by Triumvirate Environmental in Boston.  On August 27, 1999, ATC performed four test borings and installed three test wells in the vicinity of our #6 fuel oil tanks which had been cleaned and internally inspected during the Summer of 1998. Organic vapor readings and product was discovered in the immediate area. However, the fuel found was #2 and not #6. A "Background History" and "Source of Release" was conducted by ATC. The material identified was traced back to a former owner of the property, C.R. Elder Coal Yard.

An IRA was submitted to the Department of Environmental Protection by ATC on January 13, 2000 and monthly monitoring was approved through Mr. Anthony Kurpaska of the (DEP). The site has monitoring wells which are still in place, but was closed out by the (DEP).


1-0013847 (DEP Tracking Number) 

March 24, 2001 – At the request of ATC, Physical Plant Staff was called in to investigate #6 Fuel Oil in the #2 monitoring well, northeast of the #1 Sulfurated Oil tank at the New Power Plant.  All other monitoring wells were checked without a problem found.  Samples of the #6 oil were taken to determine if the sample was #1 or #2 Sulfurated Oil. The results determined it to be #1 Sulfurated Oil.  Mr. Jim Brassord was notified at 1145 hrs.  The contamination was reported to DEP at 1205 hrs (within the 2 hour  notification requirement).  Mr. Ben Fish of DEP concurred with plans to drain the problematic tank and asked to bail or otherwise remove the #6 Fuel Oil from the monitoring  well and watch for recharge.  At 1430 hrs Physical Plant Staff began transferring the oil from the #1 Sulfurated Tank to the #2 Sulfurated Tank.  The situation was turned over to Mr. Anthony Kurpaska of DEP who is responsible for the #2 Fuel Oil clean up. Amherst College has properly managed 9,600.03 tons of soil from historical #2 fuel oil contaminated site on the North side of the Amherst College Heat Plant at 151 College  Street in Amherst.  The soil was taken to Ted Andrich Construction Company from the site referenced above from June 6, 2001 to July 20, 2001.  There were 309 loads taken under the Bill of Lading. See BWSC – 012C.  Release Tracking # 1-13105.  The Licensed Site Professional overseeing the operation was Timothy J. O’Brien of ATC Associates in East Longmeadow, MA.  As part of the site clean-up, Amherst College has opted to remove the two (2) 27-year old, single wall, 50,000-gallon #6 fuel oil tanks, even though they were not identified as part of the site clean up. These were removed July 3, 2001.  The two (2) new 30,000-gallon double walled steel tanks with monitors were installed and tested on July 9, 2001 under the direction of Terry Kennedy of Bolduc Mechanical of Chester, MA.  Information on the new 30,000-gallon tanks, the permits, the field-testing certification, Tank Tightness Certification, Corrosion Protections Testing and all other pertinent documentation is on file at the Amherst College Physical Plant.  Wells have been installed around the site as identified on the site plan by ATC Associates.  The results of the testing to-date have shown the wells to be clean.


Completed IRA report on file with DEP April 2001.
Completed IRA report on file with DEP July 2001.


1-0013847 (DEP Tracking Number)

Amherst College maintains (2) separate facilities for the storage of spill control equipment and clean-up materials:


Power Plant

• 151 College Street
  

Hazardous Material Storage Building - Bay 1

• 2 East Drive, north of the Physical Plant Garage
  


The above referenced areas have supplies in sufficient quantity to control most of our spills with the exception of a catastrophic release from one or both of our 30,000 gallon (#2 or #6) fuel oil tanks which are located on the North side of our Power Plant.  Items found at both the Power Plant and the Hazardous Material/ Storage Facility and equipment storage area in the Physical Plant, Rm 001A include, but are not limited to;


Open head (DOT approved) metal drums - 55 gallon 4

Closed head (DOT approved) metal drums - 55 gallon 4

Open head (DOT approved) metal drums - 30 gallons 4

Oil and water absorbent pads 100/pkg 3 

Oil and water absorbent booms (assorted sizes 3 – 25’) 10/pkg 5 

Oil only absorbent pads 100/pkg  3 

Oil only absorbent booms (assorted sizes 3 – 25’) 10/pkg 3 

4 mil plastic bags – 15 gallon size 100/box 2 

4 mil plastic bags – 55 gallon size 100/box 2 

Oil absorbent in bags (20 lbs) 3 

Acid / Corrosive absorbent pads 100/box 1 

Acid / Corrosive absorbent booms 10/pkg 1 

Assorted steel toe oil/chemical resistant boots (size 9-13) 1 pr each size 

Assorted plastic coated Tyvek suits (Large to XX-Large) 24 

Assorted oil resistant PVC coveralls with hoods 3 

Non-sparking tools 

Plug-n-Dike repair for leaking drums and tanks 2lb.  2 

Assorted hazardous materials emergency response publications 

Oil / solvent compatible pumps 2 

pH paper  (roll)  3 

Exhaust / Supply power ventilator with detachable ductwork 2  

Negative Air Machine 1

Confined Space Equipment (tripod, harnesses etc.) 

(4) gas monitors – Crowcon  2 

(30) gas monitor – AIM 3250 1 

Ammonia/Chlorine Monitor 1

NOX/SOX Monitor 1

MiniRAE 2000 PID Gas Detector 1



Amherst College currently has and updates an oil discharge, leak, rupture or spill notification flow chart (see appendix I) that is available to anyone upon request. The main copy is located at the Amherst College Campus Police Department for reasons of quick reference and application. Other copies are located in the procedures manual for hazardous materials which includes the Community Right-To-Know, the Emergency Response Protocols and the Contingency Plans which are required by the Federal EPA and the State DEP.

All releases of oil or associated products in amounts greater than or equal to (1) gallon shall be reported to the Amherst College Physical Plant through the Amherst College Campus Police.


542-2291 (non emergency)

542-2111 (emergency)
=> The Amherst College Campus Police must immediately notify each appropriate Physical Plant Manager/Supervisor.  The scope, size and potential environmental impact will dictate who and how many people will be contacted.

The flow chart for the type of incident will assist with the above referenced task


• The most senior manager / supervisor for that particular incident will assume the role of incident commander until relieved by the College President, the Director of Facilities Management and Planning, their designee or the highest ranking member of the Amherst Fire Department (on site) 
• Until relieved by a responsible manager / supervisor, the College President, the Director of Facilities Management and Planning, their designee or the Amherst Fire Department, the most senior Amherst College Police Officer shall assume the role of incident command.

If  the Amherst Fire Department has responded to the incident, Massachusetts General Law (Chapter 148) and (527 CMR 1) mandate that they assume the role if Incident Command.


The authorized Amherst College representative or their designee shall assist the Amherst Fire Department Incident Commander with information and the appropriate resources to help prevent illness or injury and lessen the damage to the environment. 



Amherst College began the removal of all underground storage tanks several years ago. Except for the new double walled, monitored tanks that have already been identified at the Physical Plant Garage, the Lord Jeffery Inn and the (2) 30,000 gallon tanks to the north of the Heating Plant no other underground storage tanks to our knowledge exist anywhere on the Amherst College Campus. All faculty houses, owned or recently sold by the college have either been converted over to gas (natural or propane) or have had the oil storage tanks relocated to the basement.
For health and safety reasons the following plan has been incorporated to reduce potential environmental risk…

• Faculty Houses with the 275 gallon (#2) fuel oil tanks in the basement are inspected by;
  

1. the renter of the property 
2. the Oil Company that services the equipment once each year 
3. Amherst Rental Housing upon request or while on site for other reasons 
4. Environmental Health & Safety during hazard inspections

• Dormitories with up to (3) 330 gallon (#2) fuel oil tanks in the basement are inspected by;
  

1. Physical Plant Mechanical Shop
2. The Oil Company responsible for service, annually
3. Environmental Health & Safety
   
   

• Above ground tanks (excluding residential) for the storage of diesel fuel, gasoline and oil have all been replaced, including the 3 year old 1000 gallon diesel storage tank on the Southeast corner of the Old Power Plant, 10 East Drive.

• The diesel tank referenced above was replaced/removed during August 2007
  
• The new 3000 gallon tank has adequate secondary containment, proper protective barriers and appropriate signage.

 

• The Hazardous Waste Storage Facility located at 2 East Drive on the North side of the Physical Plant Garage is a (4) bay locker type building specifically designed for hazardous materials and waste.
  
  • Each bay has a self-contained sump / overflow reservoir for the containment of spills.
  1. each reservoir is designed to fully contain the intended storage
     
  2. the reservoirs can be easily pumped out and will not permit a release to the exterior

The contents of Bays 1, 2 and 3 will not be used for the storage of hazardous waste.         

• Bay 1 – Spill control and containment equipment and supplies
  
• Bay 2 - Empty drums
• Bay 3 - Batteries, Ballast’s and Universal Waste
             
  
  

Except for personnel health and safety, no other condition will take precedence over a potential environmental hazard such as a chemical or oil release.

If a chemical, oil or other hazardous material spill occurs on campus..


Insure your personal safety and the health and safety of others
- Evacuate if conditions warrant

Notify the Amherst College Campus Police at 542-211
- The Campus Police shall notify Physical Plant Personnel identified on the Oil or Chemical Spill Flow Chart


If the spill can be controlled or contained without risk to faculty, staff or students, perform the required corrective action.

If fire or the potential for fire is present...

EVACUATE the area

If the spill has the potential for each a drain, catch basin, sanitary sewer, brook, conservation area or river, every attempt should be made to limit negative environmental impact
Contact Environmental Health & Safety via the Amherst College Campus Police
- The proper equipment and supplies are available for containment and clean-up activities

- If the chemical spill or oil spill can not be contained, controlled or cleaned up by the Physical Plant, the following companies can be requested for additional assistance:


Environmental Health and Safety
Physical Plant
6 East Drive
Amherst College
(413) 542-8189 or (413) 549-0895 (home) or (413) 530-8782 (cell)


Triumvirate
63 Inner Belt Rd
Somerville, MA 02143-0003
(617) 628-8098
(617) 620-8099 (fax)