Environmental Health & Safety

Risk Management Plan (RMP)

Plan Review Required – 5 Year

October 01, 2021

Regulatory Authority(s)

  • Environmental Protection Agency (EPA)
  • Amherst Fire Department

Regulations Applicable

  • Clean Air Act, section 112
  • Massachusetts Fire Prevention Code, 527 CMR 1
  • National Fire Protection Association (NFPA 58)

Noncompliance Enforcement

  • Monetary penalties for noncompliance with the Clean Air Act are typically $37,500/day for each violation. However, the new penalty amounts are calculated using the following formula
  • Penalty = (Economic Benefit) + (Seriousness of Violation) + (Duration) + (Violator Size in Net Worth) +/- Adjustment Factors.

Responsibility(s)

  • The overall responsibility for environmental compliance at Amherst College rests with the Board of Trustees and the President of the College.
  • For this plan, the following other departments and positions within the College shall assume responsibilities applicable to them.
  • Chief of Campus Operations
  • Director of Facilities
  • Facilities Supervisors responsible for the Central Energy Plant, Electrical and Mechanical Departments
  • Department of Environmental Health and Safety

Table of ContentsPage

  1. Definitions………………………………………………………………………………………………..2
  2. Applicability……………………………………………………………………………………………...2
  3. Requirements……………………………………………………………………………………………..2

3.1 Hazard Assessment………………………………………………………………………………….. 2

3.2 Health & Safety Program……………………………………………………………………………..3

3.3 Emergency Response Protocols………………………………………………………………………3

Appendix A(Propane Tank Locations and Use)…………………………………………………………….4

  1. Definitions
  • Aboveground Storage Tank (AST) - typically 100-gallon water capacity tanks located outside of buildings used for heating and emergency generator operation
  • Liquefied Petroleum Gas (LPG) - also known as Propane
  • Underground Storage Tank (UST) - which are both 500 and 1,000-gallon water capacity tanks that are located below grade. These tanks are used as a fuel supply for emergency generators, laboratory gas jets and laundry dryers.
  1. Applicability

In accordance with the requirements of the Clean Air Act, section 112, the Federal EPA has determined that owners and operators of a facility with more than a threshold quantity of a regulated substance, as identified from the list of toxic and flammable materials in 40 CFR section 68.130 must have a RMP.

  • Amherst College has onematerial that meets the threshold for inclusion into the RMP
  • Propane

3. Requirements

The RMP must include the following;

3.1Hazard Assessment

  • The gas that Amherst College stores and utilizes on campus, which exceeds the 10,000lb RMP requirement is Propane.
  • Propane gas tanks range in quantity from 100 to 1,000 gallons
  • 100 gallon tanks are located above ground (AST) and are used for both heating and emergency generators
  • 500 gallon tanks are located below grade (UST) and are used for gas jets in laboratories and emergency generators1,000 gallon tanks are all located below grade (UST) and are used for large commercial dryers and emergency generators
  • Amherst College maintains a spread sheet with the exact locations, quantities and uses of propane gas.
  • Amherst College must secure permits for the installation of all propane gas tanks, both aboveground (AST’s) and buried tanks (UST’s) from the Amherst Fire Department.
  • The application for permit is filed by the propane tank installer.
  • Once the propane tank is placed, even below grade, the Amherst Fire Department is notified to perform the required inspection, which includes, but is not limited to identification of appropriate DOT container, location and placement, protection from physical damage, container supports, markings, piping and emergency shut-offs, in accordance with the requirements of 527 CMR 1, Chapter 69
  • In the last five years there have been no accidents or releases of propane.
  • AST’s are inspected frequently and replacements are made when potential problems are identified.
  • In the last five years two (100 gallon) AST’s were replaced because of age, and one (500 gallon) UST’s for issues involving the regulator and pressure gauge.

3.2Health and Safety Program

  • All AST’s of Propane are inspected regularly, as they are in close proximity to buildings.
  • AST’s are labeled and are filled routinely by licensed gas companies as they are utilized for emergency generators and heating.
  • Tanks that are found to be deficient, such as unsafe location or placement are relocated or replaced by the propane distributor
  • Propane tanks are monitored by the Electrical and Mechanical Shops, as well as by the Office of Environmental Health & Safety, and the propane gas distributors.
  • Each of the departments referenced above are responsible for inspecting and reporting deficiencies related to propane gas tanks, both above and below grade.
  • Identified problems are reported to the Facilities Service Center, who contact both the responsible supervisors, as well as the appropriate propane gas distributors for repair or replacement.

3.3Emergency Response Protocols

  • In the event of a Propane gas leak or odor, persons at Amherst College are trained to contact the Facilities Service Center during normal business hours (Monday – Friday 7am to 3:30pm).

(413) 542-2254

  • During non-business hours, after 3:30 during the week, weekends and holidays Amherst College faculty, staff, students and outside contractors are instructed to contact the Amherst College Police Department at (413) 542-2111
  • Emergencies involving leaks, odors and spills are automatically reported the responsible departments, Amherst College Police Department, Environmental Health and Safety, and the Amherst Fire Department, depending on severity.
  • Emergency response personnel respond with the appropriate combustible and flammable gas meters to determine level of hazard and the most appropriate corrective actions, which may include evacuation based on location and/or level of gas detected.

Appendix A – Propane Tank Locations and Uses