Environmental Health & Safety

Risk Management Plan

October 2010

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

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.

Applicability

Primary responsibility for the design, storage and use of propane gas at Amherst College rests with the department of Facilities. 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.

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 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 propane gas on site necessary, mandating 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 was 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.

Worse Case Scenario:

As referenced above, most of the propane gas at Amherst College is located below grade.  These tanks with water capacities of 1,000 gallons are located:
Academic Buildings
  • Alumni Gymnasium (NW)
  • Earth Science (NE)
  • Frost Library x2 (NW)
  • McGuire Life Science (N)
Residential Buildings
  • Appleton Hall (NW)
  • Hamilton House (W)
  • Mayo Smith House (NE)
  • Stearns Hall (S)
  • Wieland Hall (E)
Smaller 100-gallon water capacity tanks are located above ground and can be found in limited quantities around the campus.
  • A leak from the tank or regulator is possible, but a catastrophic failure of the tank would be low as the tanks are below ground

Emergency Response:

Amherst College Campus Police and Facilities Staff are trained to handle incidental chemical spills and gas leaks. The College gas monitoring equipment that is calibrated annually for proper function and response.
  1. Gas leaks are reported to Environmental Health & Safety, the Facilities Service Desk and Campus Police.  Environmental Health and Safety and/or Campus Police will respond immediately.
  2. Using the proper gas detection equipment 4 Gas Monitor or PID, a representative of Amherst College Emergency Response 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 the emergency over to the fire department incident commander.
  6. No person or persons shall be allowed to re-enter the evacuated building until  permission has been granted by the fire department incident commander and the Amherst College Campus Police.