Document 15zN4RNE8j7Vy48Ybm5qxzbra

United States Environmental Protection Agency / Region 4 Risk Management Program Inspection Report Ideal Chemical & Supply Co. Memphis, Tennessee August 18, 2021 1.0 Introduction The U.S. Environmental Protection Agency's efforts to reduce the likelihood and severity of chemical accidents includes planning and legislative initiatives such as the National Contingency Plan, the Emergency Planning and Community Right-to-Know Act (EPCRA), and the Accidental Release Prevention requirements under Section 112(r) of the Clean Air Act (CAA), as amended in 1990. This report outlines an inspection of the Risk Management Program (RMP) as mandated by Section 112(r)(7) of the CAA. The focus of this inspection was to assess the RMP for the chemical storage and distribution process at the Ideal Chemical & Supply Co. facility located in Memphis, Shelby County, Tennessee. This facility was selected for inspection because it hasn't been inspected within the last five years under the RMP. The inspection, which was conducted on August 18, 2021, consisted of an examination of program documentation as well as site reviews of various aspects of facility operations. Personnel from the facility participated throughout the inspection. Numerous documents were provided for review off-site. This report will provide a background of the facility and a listing of observations. 2.0 Background The Ideal Chemical & Supply Co. facility is located in Memphis, Tennessee. The facility stores and distributes chemicals including aqueous ammonia (conc 20% or greater). The process is regulated as program level 2. According to facility records, the facility has a maximum of 56,800 pounds of aqueous ammonia (conc 20% or greater) on site. The chemical storage and distribution process at the facility is subject to the RMP requirements of 40 C.F.R. Part 68 and EPCRA Section 302. The background specifics are summarized as follows in Table 1. TABLE 1: Inspection Information Summary Inspection Team Lead Inspector: Jordan Noles, EPA Inspector-in-Training: Bethany Terpin, EPA Date of Facility Visit: August 18, 2021 Facility Identification Name: Ideal Chemical & Supply, Co. Street Address: 4025 Air Park Street City: Memphis County: Shelby EPA Facility ID No: 1000 0007 4126 Dun & Bradstreet (D&B) No: 7040348 Latitude: 35.038611 Longitude: -089.932222 State: Tennessee Zip: 38118 Name, address, and phone of corporate parent company: Owner/Operator: Ideal Chemical & Supply Co. Mailing Address: 4025 Air Park Street City: Memphis State: Tennessee Zip: 38118 Phone: (901) 363-7720 Name, title, and email of person responsible for 40 C.F.R. Part 68 implementation: Name: Kelly McCabe Title: Vice President - Operations Phone: (901) 363-7720 Email: kmccabe@idealchem.com Name and title of emergency contact: Name: Kelly McCabe Title: Vice President - Operations Day phone: (901) 363-7720 24-hour Phone: (901) 277-2422 Email: kmccabe@idealchem.com Name and titles of stationary source personnel involved in site inspection (accompanied site tours, provided documents and explanations): Name: Kelly McCabe Title: Vice President - Operations Phone: (901) 363-7720 Email: kmccabe@idealchem.com Name: Gabrielle Scranton Title: Environmental Engineer-in-Training Phone: (907) 372-7962 Email: gscranton@ensafe.com Name: Kevin Arick Title: Senior Project Manager, Compliance Services Phone: (901) 372-7962 Email: karick@ensafe.com Page 2 of 4 Ideal Chemical & Supply Co., Memphis, TN CAA 112 (r), Risk Management Program, Inspection Report Note: This is a union facility. Date and Program Levels of Submitted Risk Management Plan Date of initial submission: June 21, 1999 Date of most recent submissions: July 13, 2021 Process: Aqueous Ammonia Storage Process ID: 1000116230 Program Level as reported in RMP: 2 NAICS code: 42469(Other Chemical and Allied Products Merchant Wholesalers) 3.0 Observations The inspection of the Ideal Chemical & Supply, Co. facility evaluated various sections of the RMP regulations (40 C.F.R. Part 68, Program Level 2) and the inspection checklist included in "Guidance for Conducting Risk Management Programs Inspections under Clean Air Act Section 112(r)." The inspection included discussions with the facility representatives regarding a myriad of issues related to the operation of its chemical storage and distribution process, the facility's RMP, a review of paperwork associated with the facility's most recent Risk Management Plan, and a tour of the facility. An inspection in-brief and out-brief were conducted. There were no findings of note as a result of the inspection. Page 3 of 4 Ideal Chemical & Supply Co., Memphis, TN CAA 112 (r), Risk Management Program, Inspection Report Inspection Report, Prepared by: JORDAN Digitally signed by JORDAN NOLES N__O__L_E__S________09_:2_2_:5_5 _-0_4'_00_' _____ Date: 2021.10.15 Jordan Noles, Inspector North Air Enforcement Section U.S. EPA Region 4 ________ Date Approved by: Digitally signed by JASON JASON DRESSLER DRESSLER ________________________D_a_te_:_2021.10.15 10_:0_1_:0_9_-_0_4'_00' Jason Dressler, Chief Date North Air Enforcement Section U.S. EPA Region 4 Page 4 of 4 Ideal Chemical & Supply Co., Memphis, TN CAA 112 (r), Risk Management Program, Inspection Report