SAFTENG NOTE: This is the first time I have come across a citation from either OSHA or EPA where they took issue with the Ammonia Flammability Limits as depicted on the NFPA 704 Diamond located on the engine/machinery room door. The facility had not updated their label to show NH3 as an F=3 for indoors; thus they still had a 1 in the RED section. The EPA referenced the IMC in their citations, and this is correct that the IMC differentiates between INSIDE and OUTSIDE for NH3 flammable ratings in the NFPA 704 Diamond; however, this facility could have taken in their SDS for their ammonia and merely stated: “we were using our SDS to establish our ratings.” I’m guessing it was just easier to change every engine/machinery room door in the company so that the NFPA Diamond Flammability is a “3”!!!! And to be sure the record is corrected… NH3 does NOT have a Flash Point as it is a GAS!
Respondent operates a food service distribution facility that includes refrigerated spaces that utilize 26,000 pounds of anhydrous ammonia within an ammonia refrigeration system. Respondent has registered an RMPlan with the EPA for its stationary source and has developed an RMProgram accidental release prevention program for the fixed source showing the process is an RMProgram level 3 covered process. On March 23, 2017, the EPA conducted an onsite inspection of the RMProgram related records and equipment to assess the Respondent’s compliance with the RMProgram requirements and the implemented recognized and generally accepted good engineering practices (RAGAGEP). At the time of the inspection, the EPA determined there were issues with…
- Engine/Machinery room visual alarm(s)
- Engine/Machinery room NFPA 704 Diamond Rating for NH3 indoors (referenced the IMC)
- Not doing Compressor Oil Analysis per manufacturer’s frequency, nor more frequency based on their previous test results
- Issues with the “Daily Rounds” not including a check on the “auto-purgers” (IIAR Bulletin 110) and not tracking oil going into/out of the process
- Did not correct issues noted during some MI inspections/testing
- Not doing MOCs on temporary evaporator coil replacement and starting, but not finishing, a MOC on a change on instrument panels
Here is a break down of the citations: