Environmental Health and SafetyEnvironmental Compliance

Risk Management Plan

I.
 Scope
II.
 Purpose
III.
 Applicability
IV.
 General Requirements
V.
 Worse Case Scenario
VI.
 Emergency Response

I. Scope

In accordance with the requirements of the Clean Air Act, Section 112(r), OSHA, NfiPA 58 and the Massachusetts Fire Prevention Regulations, a Risk Management Plan for Amherst College has been developed to help prevent a serious chemical accident that could affect the health and safety of the community as well as damage the environment. The plan is designed to prevent an incident that involves the release of propane gas. The plan is mandated by the federal Environmental Protection Agency (EPA) when a retailer or user stores more than the threshold amount of certain chemical, in the case of Amherst College the material that triggers the requirement is the propane utilized for heating and emergency power
II. Purpose
The rule requires Amherst College to develop and to implement an integrated system to identify hazards and manage the potential risks. The rule also requires that we analyze our worse case releases, document our five year history of serious accidents, coordinate with our local emergency response agencies and file this Risk Management Plan with the federal EPA.
III. Applicability
Primary responsibility for the design, storage and use of propane gas at Amherst College rests with the department of Physical Plant. It is their responsibility to inspect, maintain and when necessary repair or replace containers or associated equipment that is damaged or otherwise deficient. With the assistance of the local fire department, Amherst College places tanks above or below grade for service to emergency generators or heating equipment. When installed, the College requests and obtains a permit or license to from both the fire department and gas inspector for the storage and distribution of said gas.
IV. General Requirements
An air quality Risk Management Program is required for any facility that stores more than the threshold amount of certain listed chemicals on site. In some cases those chemicals may be found in laboratories, containers or storage tanks. Gases such as ammonia and chlorine are included on the list, but the quantities stored at Amherst College are well below the limits set by the EPA.

The most common chemical stored on site that would trigger this regulation is Propane. Amherst College handles, stores or uses propane gas in excess of 10,000 lbs. This would be equivalent to a single 2,500 gallon water capacity tank. Amherst College has the amount of gas on site necessary to place us under this regulatory requirement.

In accordance with the requirements of the Amherst Fire Department, the State Fire Prevention Regulations and the Massachusetts State Gas and Plumbing Codes, Amherst College: designs, installs, inspects and maintains propane gas tanks (above and below ground) in compliance with the NFiPA 58.

Amherst College is required to submit this Risk Management Plan to the EPA on or before June 21, 1999. As outlined in the Risk Management Plan, Amherst College has met the requirements of a Program 1 Facility. Our potential for release is less of a concern to the general public because most of the propane on site is below grade.
 
 

V. Worse Case Scenario:
As referenced above, most of the propane gas at Amherst College is located below grade. Tanks with water capacities of 1,000 gallons can be found on the northwest corner of Frost Library, the northwest corner of Alumni Gymnasium and between Pratt Museum and the Merrill / Life Science Complex. Smaller 100-gallon water capacity tanks are located above ground and can be found in limited quantities around the campus. Amherst College has not had an incident involving a propane gas tank in the last five or more years. The design, installation and oversight involved using the requirements set forth in NFiPa 58 should mitigate that chances of that type of incident happening at the College.
 
VI. Emergency Response:
Amherst College Physical Plant Staff are trained to handle incidental chemical spills or gas leaks. The College has at its disposal gas monitoring equipment that is calibrated annually for proper function and response.
  1. If a gas leak of any kind is reported to either the Physical Plant Service Desk or the Amherst College Campus Police, the Physical Plant staff will immediately respond. If not the Office of Environmental Health and Safety, then the Mechanical Shop shall handle.
  2. Using the proper gas detection equipment (AIM 3000), a representative of the Physical Plant will determine the hazard or potential hazard of the leak. - if possible, the gas will be turned off - if not possible windows and doors will be opened to properly ventilate the area and therefore reduce the concentration until repairs to the system can be made.
  3. If the gas detection equipment indicates levels greater than 10% of the LEL, the inspector, plumber or HVAC mechanic will immediately notify the Amherst Fire Department, through the Amherst College Campus Police.
  4. The building or area will be evacuated by protocol - See Emergency Action Plan
  5. As soon as the Amherst Fire Department arrives on the scene, the on-site representative of the College turns over the emergency to them.
  6. No person or persons shall be allowed to re-enter the evacuated building until the fire alarm has (if used) been silenced and permission has been granted by the fire department incident commander or the Amherst College Campus Police.