Environmental Health & Safety

Spill Prevention, Control and Countermeasure Contingency Plan Certificate and Facility Acceptance


March 2008

In accordance with the United States Environmental Protection Agency Regulations regarding oil pollution prevention, Amherst College as a Tier III facility, has prepared this Spill Prevention, Control and Countermeasures plan, here-after known as the SPCC plan, in compliance with (part 112, 40CFR) and revisions of July 17, 2002.

Under the Clean Water Act, the Environmental Protection Agency (EPA) can conduct compliance inspections of a facility for which an SPCC plan is required. Because Amherst College is the owner/operator of a non transportation facility with above ground oil storage in excess of 1,320 gallons and located in such an area that can reasonably be expected to discharge oil into a brook or river, the plan is relevant.

The Amherst College SPCC plan has taken into consideration Oil Spill Prevention and Response. As outlined in Facilities Response Plan section of 40 CFR, Amherst College has met all of the requirements of both the "Elements of a Model Plan" and the "Critical Elements of a Plan". The program contains an action plan, is cross-referenced with other policies and procedures and is facility specific.

Copies of the SPCC Plan are located in, and can be obtained from the Treasurer's Office, the Physical Plant (Office of the Director, EH&S and the Campus Police). Additional copies as required are located it the Town of Amherst at the following departments; Board of Health, Conservation Commission, Fire and Public Works. Most of the above referenced departments are open at least 8 hours per day, but 24-hour access to the SPCC plan is possible through either the Amherst College Campus Police or the Amherst Fire Department, if needed.

As necessary, the SPCC plan will be amended if and when a change in the facility design, construction, operation or maintenance affects the potential for a discharge of oil into the environment. If a change in the facility does not take place, and there are no new technological advances in oil spill prevention and control, then Amherst College will review and update the SPCC plan every (5) years, as required.

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.

Engineer's Signature

 

Table of Contents



SPCC Plan Purpose:

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

Definitions:

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.

Scope:

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

Applicability

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;
    • Fearing Brook, East of Hills Parking Lot
    • Fort River, South of the campus
    • Hadley Reservoir, North of the Bunker
    • Harts Brook, West of University Drive
    • 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
    • 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.

Responsibility

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 notifcation procedures.

Facility Inspections - depending on the hazard, location of hazard and control measures in place, which inlcude 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 distrubute 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 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 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
  • whenever the operation of the facility or its storage, use or transportation of oil is altered
  • 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.

Facility Description  

#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
  1. 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 preheater 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.

  1. Test the overfill alarm by pressing the “TEST” button. The tank lights should illuminate and the horn sound.
  2. Open the Cofferdam door on the tank to receive the delivery and inspect.
  3. 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.

  1. 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. 
  2. 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.

Physical Plant Garage, 2 East Dr.

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

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.
  • 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.

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 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 new 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 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:

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.

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 or 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

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.

Universal Waste Facility

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 with floors that have 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 stell Roth Tanks.

Hypothetical Situations:

Underground Storage Tanks
- Leaks, Overflows, Ruptures or Spills

The underground tank for the Lord Jeffery Inn has recently been replaced with a double wall tank and monitoring devices to detect leaks. 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.

The (2) 30,000-gallon underground tanks for the storage of #2 and #6 fuel oil at the Power Plant are 6 years old to date, installed in 2001. 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 are still present – Summer 1999. They were left in place after the 26 year old tanks were removed last summer, 2001 See Spill History Log for August 1999 (Page 26, item #12)

The underground oil separator located outside the Power Plant and Physical Plant on the Northeast corner of the garage could plug. If this were to happen, 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 and then into a waterway via a storm drain or downhill flow. 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.

Spill History  

 

According to the report given by the Massachusetts Department of Environmental Protection, Amherst College has experienced the following "reportable quantity" releases:

The project was closed out on July 26, 1988

  • W88-0284 (DEP Tracking Number)

The project was closed out on November 01, 1991

  • W91-0359 (DEP Tracking Number)

The project was closed out on July 30, 1993.

  • W93-0401 (DEP Tracking Number)

The project was closed out on October 6, 1995.

  • 1-10103 (DEP Tracking Number)

The project was closed out on April 5, 1994.

  • 1-0010231 (DEP Tracking Number)

The project was closed out on April 15, 1999.

  • 1-0010292 (DEP Tracking Number)

The project was closed out on September 29, 1994.

  • 1-0010489 (DEP Tracking Number)

The project was closed out on March 22, 1996.

  • 1-0011214 (DEP Tracking Number)

The project was closed out on July 07, 1997.

  • 1-0011802 (DEP Tracking Number)

The project was closed out on January 5, 1998.

  • 1-0012073 (DEP Tracking Number)

The project was closed out on August 21, 1998.

  • 1-0012236 (DEP Tracking Number)
  • 1-0013847 (DEP Tracking Number)
  • Completed IRA report on file with DEP April 2001.
  • Completed IRA report on file with DEP July 2001.
  • 1-0013847 (DEP Tracking Number)

Spill Control

    • 151 College Street
    • 2 East Drive, north of the Physical Plant Garage
    • 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.
  • 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.

  1. Bay 1 – Spill control and containment equipment and supplies
  2. Bay 2 - Empty drums
  3. 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.
  1. If a chemical, oil or other hazardous material spill occurs on campus.. 
  2. Insure your personal safety and the health and safety of others

Contingency Plan and Location(s)

Amherst College has identified potential risks, storage sites, regulatory requirements, control and containment equipment and structures that were designed to limit or significantly reduce negative environmental impact in accordance with 40 CFR 112.7. The College believes that through careful planning, removal of old underground storage tanks and a proper inspection program we can and will prevent most if not all releases of oil. However, a contingency plan has been implemented to further protect the college from unforeseen potential risk.

The plan as required by the federal EPA is available on our website, http://www.amherst.edu/~ehs, has been submitted to the...

  1. Amherst Fire Department
  2. Amherst Local Emergency Planning Committee via Assistant Chief Michael Zlogar
  3. Amherst Board of Health
  4. Amherst Department of Public Works
  5. Amherst Conservation Commission


A summary of the notification requirements is included as part of the SPCC/Contingency Plan and a copy of the Spill Incident Report Form is included in section XIII of this plan.

Plan Review

As required by federal regulation, Amherst College will review, evaluate and amend this plan every (5) years or as necessary when...

  1. a more effective prevention and control technology has been developed 
  2. 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 Massachusetts Registered Professional Engineer at least triennially.

Security

    • unsecured hazardous material or waste storage areas
    • the accidental or potential release of chemicals or oil
    • the improper identification or containment of hazardous materials or waste
    • the improper storage, transportation or use of hazardous or universal materials or waste.
    1. Keys to the Hazardous Waste Storage Facility have been given to each Physical Plant Supervisor and can also be obtained through the office of Environmental Health & Safety and the Amherst College Campus Police.
    2. Limited access to this facility is designed to prevent the improper placement of hazardous and universal waste in the facility without the knowledge of those responsible.

    1. Persons needing access to these areas should contact the appropriate shop supervisor or elevator repair technicians.
    2. Elevator technicians can acquire their keys for access to campus elevator machine rooms and pits from the Amherst College Campus Police Department, located at the Physical Plant, 6 East Drive.

Inspections

    • Inspections of all oil storage facilities, elevator pits, tanks and containers must be performed in accordance with the SPCC / Contingency plans. Inspection frequency is dependent on the location, size and access to the container, elevator pit and tanks.
    • Inspections of each container, elevator pit and tank shall be the responsibility of the appropriate shop supervisor and their staff, the elevator contractor(s), the Heat Plant Lead Engineer and staff and Environmental Health and Safety.
    • Underground storage tanks at the Lord Jeffery Inn (#2 Fuel Oil) is a double wall tank that is monitored with audible alarms. In the event of a leak, alarms will sound indicating a problem.
    • The new 3,000 gallon diesel fuel tank for heating equipment at the Amherst College Book Depository on Military Road is also a double wall tank with monitoring system. The Amherst College Campus Police Dispatch Center supervises this particular tank electronically 24 hours a day, 365 days a year.

  • The office of Environmental Health and Safety and the Power Plant (New Steam Plant) shall maintain records for the above referenced inspections.
  • The above ground oil storage tanks in apartments and houses rented by faculty and administrative staff shall be incorporated into the TMA work order system.
    • These yearly inspections, performed in addition to the contractor service call will be performed by either the Physical Plant Mechanical Shop or Environmental Health and Safety.
  • The switch and transformer inspection that shall be performed at least annually by the Physical Plant Electrical Shop and will be incorporated into the TMA Work Order System.

Personnel Training 

Physical Plant personnel receive training in many different areas of health and safety, including small scale (level C) hazardous material response for leaks, ruptures or spills of oil and other similar limited hazard types of discharge.

    • All spills of oil in amounts greater than or equal to 10 gallons are reported to the Amherst Fire Department and the Department of Environmental Protection as required.

Response personnel from Amherst College include but are not limited to:

  1. Amherst College Campus Police 
  2. Environmental Health and Safety 
  3. Mechanical Shop Staff 
  4. Power Plant Personnel, and Electrical Shop 
  5. Chemical Hygiene Officer

Personnel from the above referenced departments will be trained to…

  1. contact the appropriate Physical Plant Staff 
  2. find and use clean-up supplies in Bay 1 of the Hazardous Material Storage Building 
  3. temporarily or permanently contain, divert or clean-up the hazardous material 
  4. notify the appropriate regulatory agencies (see oil spill flow chart) 
  5. contact the appropriate clean-up companies (see oil spill flow chart)
  6. follow the flow chart that has been developed for this type of incident 
  7. locate and properly fill out the Amherst College Spill Notification Report 
  8. fill out the appropriate reports required by the Commonwealth of Massachusetts

Records of the training for Physical Plant personnel shall be kept on the TMA Work Order system for reasons of yearly notification about retraining.

The LEPC and the Municipal Coordinator (Amherst Fire Department) will be provided with a list of those personnel who have been trained to respond to and aid in the mitigation of a hazardous material incident, such as an oil spill.

An annual training exercise (full-scale or tabletop) will be performed in-house with Physical Plant response personnel. A critique of the incident will follow with alterations to the plan being made to improve our response activities and corrective action.

  • Amherst College Physical Plant will notify the Amherst Fire Department about any forthcoming hazardous material training so that the members of the fire department can participate or review our StandardOperating Procedures.
  • Training accomplishments will be entered into the TMA Work Order System with hardcopies being maintained in the office of Environmental Health & Safety.