Environmental Health & Safety

Air Quality Management Plan


January 2010


Scope:

In accordance with the requirements of the Massachusetts Department of Environmental Protection 310 CMR 7, the Clean Air Act and other applicable regulations mandated by the Federal Environmental Protection Agency, including 40 CFR 81.322, Amherst College under the direction of the Environmental Health & Safety Committees has implemented this Air Quality Management Plan for the health and safety of the faculty, staff, students, visitors, outside contractors and the community that surrounds Amherst College

Purpose:

Amherst College implemented this plan in order to lessen potential health and safety risks to the faculty, staff, students, and the community. The College will aggressively work to reduce the negative environmental impact by reviewing the types of material that we are discharging into the atmosphere and at what rate. Monitoring of our air discharges, primarily those at the Heat Plant shall be the responsibility of the Utilities Manager in the office of Design and Construction, in accordance with the regulatory requirements of the local, state and federal governments and the standard operating guidelines of the Environmental Health and Safety Committees. In addition, Amherst College will try to reduce our negative environmental impact on the air by encouraging a reduction of VOC emissions, installation of Stage I and II vapor recovery systems, encouraging ride share opportunities, monitoring ambient air, and estimating and reducing emissions.

Applicability:

The Air Quality Management Plan is the responsibility of the Heat Plant Engineer and staff, the Design and Construction Department and the Office of Environmental Health and Safety within the Physical Plant at Amherst College. The Management Policy is the responsibility of above referenced departments.

Definitions:

Hazardous Air Pollutants - Chemicals that cause serious health and Environmental effects. Hazardous Air Pollutants (HAP) are released by sources such as chemical plants, dry cleaners, printing plants, and motor vehicles

Nitrogen Oxide (NOx) - a criteria air pollutant produced from burning fuels, including gasoline and coal. NOx is a smog-former which reacts with volatile organic compounds to form smog and acid rain.

Particulate Matter (PM-10) - a criteria air pollutant - Particulate matter which includes dust, soot, and other tiny bits of matter that are released into and move around in air. Diesel fuel trucks and buses, garbage incineration, mixing and application of fertilizers and pesticides, road construction, industrial processes and operation of fireplaces and wood stoves produce particulates.

Source - any place or objects from which pollutants are released. It can be a power plant, factory, dry cleaning business, gas stations or farms. Cars, trucks and other motor vehicles are sources as well. Sources that stay in one place are called
Stationary Sources.

State Implementation Plan - The federal Clean Air Act (CAA) requires the Commonwealth of Massachusetts to adopt and submit the Federal EPA plans which implement, maintain and enforce the National Ambient Air Quality Standards.

Sulfur Dioxide- a criteria air pollutant, sulfur dioxide is a gas produced by burning coal, most notably in power plants. Sulfur dioxide is most closely related to sulfuric acid and is a chief ingredient of acid rain.

Volatile Organic Compound (VOCs) - Organic chemical (w/ carbon), VOC's are chemicals that are not produced naturally, they are synthesized by chemists in laboratories. VOC's produce vapors readily at room temperature and at normal atmospheric pressure. VOC's include gasoline, toluene, benzene, perchloroethylene, and other industrial chemicals / solvents.VOC's are hazardous Air Pollutants, some of which cause cancer.

Regulatory Requirements:

A. The Massachusetts DEP Permit Responsibilities

The Massachusetts Department of Environmental Protection, Division of Air Quality is the regulatory agency responsible for administering and enforcing the requirements for air emission permits.

B. The Massachusetts DEP Air Pollution Rules

The above referenced division of the State Department of Environmental Protection is also responsible for administering and enforcing Massachusetts Air Pollution Rules.

C. The State Implementation Plan (SIP)

The State Implementation Plan (SIP) focuses on Title V Operating Requirements, non attainment areas, hazardous air pollutants and other air related requirements.

D. Massachusetts and the Clean Air Act

The Clean Air Act (CAA) requires the State of Massachusetts to develop and implement standards for attaining the health based national ambient air quality standards (NAAQS) for the five (5) priority air pollutants: sulfur dioxide, carbon monoxide, lead, particulate matter and 10 microns or less nitrogen dioxide and ozone

E. Amherst College and the Clean Air Act

The Clean Air Act (CAA) has identified program objectives for the next couple of years. Some of these initiatives, referred to as Titles (I through V) will effect the Amherst College Campus. A breakdown of the titles is as follows:

  1. Title I (Non-Attainment)
  2. Title II (Mobile Sources)
  3. Title III (Air toxics)
  4. Title IV (Acid Rain)
  5. Title V (Federal Enforcement)

Permits

A. The DEP and EPA Permits

The State DEP permit is quite similar to the permit which is used by the Federal EPA.

B. Exemptions to Operating Permits

Some sources, including stationary power plants are not required to apply for an operating permit under the National Emissions Standard.

C. Amherst College Permit Status

Because Amherst College generates less than 1/2 the total tonnage of the hazardous air pollutants at the Heat Plant we are not be required to have a permit.

  • Currently, Amherst College is working under the blanket of a "Restricted Emissions Status", with the approval of the State Department of Environmental Protection

Permit Requirements

Any facility where the construction, substantial reconstruction, or alteration of the facility would result in an increase of 5 tons or more per year or more of either a criteria pollutant or the sum of a non-criteria pollutants.

A. Plan Approvals
  1. Fuel utilization facilities, excluding internal combustion engines
  2. Internal Combustion Engines with an energy input capacity of 3,00,000 Btu/hour or more
  3. Any facility that would violate a condition of any plan approval by increasing the potential emissions by 5 tons or more per year.
  4. Any facility which the DEP determines to have the potential for causing or contributing to a condition of air pollution
  5. Any incinerator
  • In order to obtain comprehensive plan approval, an applicant is required to follow the guidelines listed in 310 CMR 7.02

Permit Exceptions

Amherst College is permitted to exempt the following activities from the requirements of the operating permit program (310 CMR 7.00, Appendix C (5) (1).

A. Possible Exemptions to the Operating Permit Program.
  1. Regulated open burning
  2. Office activities, including the use of office machines
  3. Interior maintenance activities
  4. Bathroom and Locker Room Ventilation and Maintenance
  5. Maintenance Shop Activities
  6. First Aid or Emergency Care
  7. In House Laundry Operations
  8. Repainting, reroofing and/or sandblasting
  9. Grounds keeping Activities (lawn and parking lot maintenance)
  10. Food Preparation
  11. Use of portable space heaters
  12. Fuels to power the facility's mobile equipment
  13. Emergency Vents
  14. Surface coating and venting processes excluding spray cans
  15. Commercial and Residential Vacuum Cleaning Systems
  16. Heating and Cooling Ventilation Systems
  17. Laboratory Fume Hoods
  18. Surface Coating and Printing for Educational Purposes
  19. Kilns or Ventilation Hoods for Educational Purposes