houstonlogo rjilogo

The Right-to-Know Network

Back to search

Cornerstone Chemical Company

Parent Companies:
EPA Facility ID:
100000156127
Other ID:
70094MRCNC10800
Facility DUNS:
967512810

Location:

Address:
10800 River Road (LA Hwy. 18)
Waggaman, LA 70094
County:
JEFFERSON
Lat / Long:
29.959, -90.270 (Get map)
Method:
Interpolation - Photo
Description:
Facility Centroid
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Cornerstone Chemical Company
Phone:
(504) 431-9511
Address:
10800 River Road (LA Hwy. 18)
Waggaman, LA 70094
Foreign Address:

Person responsible for RMP implementation:

Name:
Paul Mikesell
Title:
Chief Operating Officer

Emergency contact:

Name:
Paul Mikesell
Title:
Chief Operating Officer
Phone:
(504) 431-6515
24-hour phone:
(504) 431-9511
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
(504) 431-9511
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Jefferson Parish
Full-Time Equivalent Employees:
469
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
Yes
CAA Permit ID#:
See Exec. Sum.
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
Oct. 31, 2017
Inspecting Agency:
OSHA
Using Predictive Filing:
No

Processes:

Acrylonitrile Plant
RMP ID:
1000079919
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Hydrocyanic acid
74-90-8
230,000
No
Ammonia (anhydrous)
7664-41-7
970,000
No
Flammable Mixture
00-11-11
6,500,000
No
Acrylonitrile [2-Propenenitrile]
107-13-1
3,800,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Melamine Plant
RMP ID:
1000079920
CBI claimed:
No
Program Level:
3
NAICS:
All Other Basic Organic Chemical Manufacturing (325199)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
210,000
No
Public OCA Chemical
0
No
Sulfuric Acid Regn. Plant
RMP ID:
1000079921
CBI claimed:
No
Program Level:
3
NAICS:
Other Basic Inorganic Chemical Manufacturing (32518)
Chemical name
CAS#
Quantity (lbs.)
CBI
Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide]
8014-95-7
2,800,000
No
Sulfur dioxide (anhydrous)
7446-09-5
7,900
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Material Services
RMP ID:
1000079922
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Acrylonitrile [2-Propenenitrile]
107-13-1
20,000,000
No
Oleum (Fuming Sulfuric acid) [Sulfuric acid, mixture with sulfur trioxide]
8014-95-7
4,200,000
No
Flammable Mixture
00-11-11
200,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Utilities
RMP ID:
1000079923
CBI claimed:
No
Program Level:
3
NAICS:
All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Chemical name
CAS#
Quantity (lbs.)
CBI
Ammonia (anhydrous)
7664-41-7
50,000,000
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Address:

,
Foreign Address:

Phone:

Latest RMP Submission:

Date:
May 26, 2017
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000063701

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Acrylonitrile Plant)
CBI claimed:
No
Percent weight:
12.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Release duration (mins):
560.00
Wind speed (meters per sec):
1.5
Stability class:
F
Topography:
Urban
Passive mitigation
considered:
  • Dikes
not considered:
  • Enclosures
  • Berms
  • Drains
  • Sumps

3. Toxics: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Acrylonitrile Plant)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Emergency shutdown
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
Public OCA Chemical (in Acrylonitrile Plant)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
not considered:
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Melamine Plant)
CBI claimed:
No
Percent weight:
100.0
Physical state:
Gas
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Sulfuric Acid Regn. Plant)
CBI claimed:
No
Percent weight:
30.0
Physical state:
Liquid
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • Dikes
  • Berms
not considered:
  • Enclosures
  • Drains
  • Sumps
Active mitigation
considered:
  • Sprinkler systems
  • Neutralization
not considered:
  • Deluge systems
  • Water curtain
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown
Public OCA Chemical (in Sulfuric Acid Regn. Plant)
CBI claimed:
No
Percent weight:
Physical state:
Gas
Model used:
EPA's RMP*Comp(TM)
Wind speed (meters per sec):
3.00
Stability class:
D
Topography:
Urban
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Enclosures
  • Berms
  • Drains
  • Sumps
Active mitigation
considered:
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Neutralization
  • Excess flow valve
  • Flares
  • Scrubbers
  • Emergency shutdown

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Acrylonitrile Plant)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Material Services)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

Aug. 14, 2017 at 08:50
ID:
1000051697
NAICS:
Petrochemical Manufacturing (32511)
Duration:
14 minutes
Chemicals involved:
  • Hydrocyanic acid
Release events:
Liquid spills/evaporation
Weather conditions at time of event
Wind speed:
8.0 miles/h SW
Temperature:
85.00 ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Human Error
Contributing factors:
  • Human error
Off-site responders notified:
Notified and Responded
Changes introduced as a result of the accident:
  • Revised training
  • Revised operating procedures
  • Re-evaluate PPE requirements and manning requirements for the activity
March 28, 2017 at 15:00
ID:
1000049297
NAICS:
Petrochemical Manufacturing (32511)
Duration:
100 hours and 30 minutes
Chemicals involved:
  • Hydrocyanic acid
Release events:
Gas release
Weather conditions at time of event
Wind speed:
7.5999999 miles/h SE
Temperature:
83.00 ℉
Atmospheric stability:
Precipitation present:
No
Unknown weather conditions:
No
On-site impacts
Deaths of employees or contractors:
0
Deaths of public responders:
0
Deaths of public:
0
Injuries of employees or contractors:
1
Injuries of public responders:
0
Injuries of public:
0
Property damage:
$0
Known off-site impacts
Deaths:
0
Hospitalizations:
0
Medicals treatments:
0
Evacuated:
0
Sheltered-in-place:
0
Property damage:
$0
Environmental damage:
Initiating event:
Equipment Failure
Contributing factors:
  • Equipment failure
Off-site responders notified:
Notified Only
Changes introduced as a result of the accident:
  • Improved/upgraded equipment

7. Prevention: Program level 3

Acrylonitrile Plant, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000067258
Safety Review Date
March 18, 2014, since latest RMP submission
PHA Update Date
March 19, 2014, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
Mitigation Systems
  • None
Monitoring Systems
  • Process Area
  • Perimeter Monitors
Changes since PHA
  • Process Parameters
  • Process Controls
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Nov. 14, 2017, since latest RMP submission
Training Review Date
Jan. 1, 2017, since latest RMP submission
Maintenance Review Date
Jan. 20, 2017, since latest RMP submission
Maintenance Inspection Date
Jan. 3, 2017, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Nov. 21, 2016
Management of Change Review Date
April 22, 2015
Pre-startup Review Date
Jan. 11, 2017
Compliance Audit Date
Oct. 24, 2016
Compliance Audit Change Completion Date
Nov. 24, 2017
Incident Investigation Date
Aug. 14, 2017
Incident Invest. Change Completion Date
Dec. 31, 2017
Participation Plan Review Date
Jan. 28, 2016
Hot Work Review Date
April 21, 2016
Contractor Safety Review Date
July 15, 2016, since latest RMP submission
Contractor Safety Eval. Date
Jan. 26, 2017, since latest RMP submission
Melamine Plant, All Other Basic Organic Chemical Manufacturing (325199)
Prevention Program ID:
1000067259
Safety Review Date
Dec. 5, 2016, since latest RMP submission
PHA Update Date
Dec. 13, 2016, since latest RMP submission
PHA Techniques
  • What if
  • Checklist
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Keyed Bypass
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Rupture Disks
  • Quench System
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 4, 2017, since latest RMP submission
Training Review Date
Jan. 1, 2017, since latest RMP submission
Maintenance Review Date
Jan. 20, 2017, since latest RMP submission
Maintenance Inspection Date
Aug. 19, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 11, 2017
Management of Change Review Date
April 22, 2015
Pre-startup Review Date
Jan. 11, 2017
Compliance Audit Date
Oct. 24, 2016
Compliance Audit Change Completion Date
Nov. 24, 2017
Incident Investigation Date
Nov. 26, 2016
Incident Invest. Change Completion Date
Nov. 28, 2016
Participation Plan Review Date
Jan. 28, 2016
Hot Work Review Date
April 21, 2016
Contractor Safety Review Date
July 15, 2016, since latest RMP submission
Contractor Safety Eval. Date
Jan. 26, 2017, since latest RMP submission
Sulfuric Acid Regn. Plant, Other Basic Inorganic Chemical Manufacturing (32518)
Prevention Program ID:
1000067260
Safety Review Date
Nov. 16, 2016, since latest RMP submission
PHA Update Date
Nov. 16, 2016, since latest RMP submission
PHA Techniques
  • What if
  • Checklist
  • What if/Checklist
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Relief Valves
  • Check Valves
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Grounding Equipment
  • Quench System
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 4, 2017, since latest RMP submission
Training Review Date
Jan. 1, 2017, since latest RMP submission
Maintenance Review Date
Jan. 20, 2017, since latest RMP submission
Maintenance Inspection Date
Oct. 12, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Nov. 10, 2016
Management of Change Review Date
April 22, 2015
Pre-startup Review Date
Nov. 17, 2016
Compliance Audit Date
Oct. 24, 2016
Compliance Audit Change Completion Date
Nov. 24, 2017
Incident Investigation Date
Nov. 21, 2016
Incident Invest. Change Completion Date
May 31, 2017
Participation Plan Review Date
Jan. 28, 2016
Hot Work Review Date
April 21, 2016
Contractor Safety Review Date
Jan. 15, 2016, since latest RMP submission
Contractor Safety Eval. Date
Jan. 26, 2017, since latest RMP submission
Material Services, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000067261
Safety Review Date
Dec. 12, 2016, since latest RMP submission
PHA Update Date
Dec. 20, 2016, since latest RMP submission
PHA Techniques
  • What if
  • Checklist
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Runaway reaction
  • Polymerization
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Purge System
Mitigation Systems
  • None
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 26, 2017, since latest RMP submission
Training Review Date
Jan. 1, 2017, since latest RMP submission
Maintenance Review Date
Jan. 20, 2017, since latest RMP submission
Maintenance Inspection Date
Oct. 26, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
April 6, 2016
Management of Change Review Date
April 22, 2015
Pre-startup Review Date
Sept. 26, 2016
Compliance Audit Date
Oct. 24, 2016
Compliance Audit Change Completion Date
Nov. 24, 2017
Incident Investigation Date
June 22, 2016
Incident Invest. Change Completion Date
July 8, 2016
Participation Plan Review Date
Jan. 28, 2016
Hot Work Review Date
April 21, 2016
Contractor Safety Review Date
July 15, 2016, since latest RMP submission
Contractor Safety Eval. Date
Jan. 26, 2016, since latest RMP submission
Utilities, All Other Miscellaneous Chemical Product and Preparation Manufacturing (325998)
Prevention Program ID:
1000067262
Safety Review Date
Nov. 10, 2016, since latest RMP submission
PHA Update Date
Sept. 27, 2016, since latest RMP submission
PHA Techniques
  • What if
  • Checklist
  • What if/Checklist
Hazards Identified
  • Toxic release
  • Fire
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
  • Cooling loss
  • Hurricanes
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Excess Flow Device
  • Purge System
Mitigation Systems
  • Dikes
Monitoring Systems
  • None
Changes since PHA
  • None
Training Type
  • None
Competency Testing
  • Written Test
  • Oral Test
  • Demonstration
  • Observation
Procedure Review Date
Jan. 18, 2017, since latest RMP submission
Training Review Date
Jan. 1, 2017, since latest RMP submission
Maintenance Review Date
Jan. 20, 2017, since latest RMP submission
Maintenance Inspection Date
June 16, 2016, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
Jan. 10, 2017
Management of Change Review Date
April 22, 2015
Pre-startup Review Date
Jan. 10, 2017
Compliance Audit Date
Oct. 24, 2016
Compliance Audit Change Completion Date
Nov. 24, 2017
Incident Investigation Date
Oct. 31, 2016
Incident Invest. Change Completion Date
June 30, 2017
Participation Plan Review Date
Jan. 28, 2016
Hot Work Review Date
April 21, 2016
Contractor Safety Review Date
April 15, 2016, since latest RMP submission
Contractor Safety Eval. Date
Jan. 26, 2017, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
Jan. 19, 2017
Local Response Agency:
Local Response Agency Phone:
(504) 349-5360
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

Executive Summary

Cornerstone Fortier Plant's Risk Management Plan

(40 CFR 68, EPA Chemical Accident Prevention Provisions)

LDEQ Facility ID Number: 1357

EPA Facility Identifier: 1000 0015 6127



Cornerstone Fortier Plant Executive Summary



68.155 (a) ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES

Cornerstone is a leader among chemical manufacturers in its safety, health and environmental

programs. Our commitment to protect our employees and the communities that are home to our

operations is an integral part of Cornerstone's way of doing business. Cornerstone has established

safety, health, emergency response and environmental policies and standards to meet or exceed all

regulatory requirements.



68.155 (b) THE STATIONARY SOURCE AND THE REGULATED SUBSTANCES HANDLED

Our facility consists of continuous manufacturing plants producing a variety of end products ,including acrylonitrile, melamine, urea and sulfuric acid. Processes at the Fortier facility that produce regulated substances are acrylonitrile, melamine, and sulfuric acid. Other departments in which regulated substances are handled include Utilities and Material Services



Acrylonitrile (Acrylonitrile Process), a regulated substance, is used as a raw material to make a variety of products such as plastics, synthetic fibers, water treatment chemicals and synthetic rubbers Other regulated substances involved with this continuous operation are propylene(with 5% propane, reported as a flammable mixture) , hydrocyanic acid, propane, and ammonia. The Acrylonitrile process creates a co-product, hydrocyanic acid (HCN) that is transferred to tenant company at the Fortier plant via pipeline. NAICS# 325199



Melamine (Melamine Process) is used to make a variety of products such as hard plastics, laminates, microwave plates, flame retardants, coatings and adhesives. The regulated substance involved with this continuous operation is ammonia. NAICS# 325199



Sulfuric Acid Regen Proces
s produces sulfuric acid, which is used in car batteries, gasoline refining, fertilizer production, paper production, and several other processes. The regulated substances associated with production of sulfuric acid are oleum and sulfur dioxide. NAICS# 325188



The Material Services Department stores and transports acrylonitrile, as well as transports propylene (with 5% Propane, reported as a flammable mixture)

and oleum via railcar within the plant. All of these chemicals are regulated substances.

NAICS#325998



The Utilities Department uses ammonia as a refrigerant. NAICS#325998



68.155 (c) THE GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICALSPECIFICPREVENTION STEPS



Cornerstone's general accidental release prevention program includes:

EPA 40 CFR 68 - Risk Management Plans

OSHA 29 CFR 1910.119 - Process Safety Management of Highly Hazardous Chemicals

OSHA 29 CFR 1910.120 - Hazardous Waste Operations & Emergency Response

Other EPA, OSHA, DOT, and State regulations



Recognized And Generally Accepted Good Engineering Practices, engineering codes and standards:



The following engineering and administrative controls have been implemented in the Acrylonitrile Plant to prevent releases of covered chemicals:



Chemicals are stored in above ground tanks contained within concrete dikes.

All pipelines and vessels are built according to engineering standards using materials fit for the service.

Area monitors are used to detect releases of propylene and hydrocyanic acid, in order to prevent offsite release.

Scrubbers and flares are used to prevent release of toxics or flammables to the environment.

Sumps and concrete containment are used to prevent contamination of the ground.

Alarms and interlocks are used to prevent out-of-control conditions, which could lead to a release.

All operators have been trained and are certified under our Process Operator Training Certification (POTC) system.

Emergency response plans are written and in place to
address the handling of releases and spills.



The following engineering and administrative controls have been implemented in the Acid Plant to prevent a release of oleum:



Both oleum storage tanks are equipped with high and "high high" level alarms. The alarms annunciate on the control panel.

Both oleum tanks are located within concrete secondary containment.

Both oleum tanks are protected from overpressure and vacuum by a conservation vent.

The oleum piping system is inspected per our mechanical integrity program. .

All operators have been trained and are certified under our POTC training system.





The following engineering and administrative controls have been implemented in Utilities to prevent releases of ammonia from the ammonia storage tank:



The ammonia is stored in an above ground tank contained within an earthen dike.

The ammonia storage tank area is visually monitored by certified operators on a daily basis.

There are numerous pressure transmitters / indicators /alarms to warn of storage tank high pressure.

The tank is automatically vented to a flare in the event of high pressure.

There are numerous level transmitters / indicators / alarms to warn of high storage tank level.

There are two emergency shut-off valves at the base of the tank to enable isolation in the event of a leak on an out-loading line.

All operators have been trained and are certified under our POTC training system.





The following engineering and administrative controls have been implemented in the Melamine Plant to prevent a release of ammonia:





Gaseous leak detection on autoclave

Pressure safety valves and rupture disks on all pressure rated vessels

Mechanical integrity inspection schedules on equipment

Vent flares

Alarms and controls in a state of the art DCS monitoring & control system

Emergency shutdown system

All operators have been trained and are certified under our POTC training system.

Fugitive emissions monitoring system



68.155 (d) THE FIVE
-YEAR ACCIDENT HISTORY

The following incidents occurred at Fortier during the past five years:



A release of crude acetonitrile containing approximately 3% HCN from a pin hole leak in a loading pipeline that came in contact with an employee causing a overnight hospitalization.



68.155 (e) THE EMERGENCY RESPONSE PROGRAM

Fortier's Emergency Procedures, which contain plant emergency response guidelines, were developed to reduce the risk of a chemical release to employees and the public. Communications are established with Jefferson Parish's and St. Charles Parish's departments of emergency management, the City of Kenner fire department, Louisiana State Emergency Response, and others as needed.



Fortier responds to incidents with a facility Emergency Response Team that is trained to First Responders Operations level. We have an automated system that can call to warn neighbors of emergency, as well as call in additional Cornerstone personnel if needed in the event of an emergency. We also have access to a parish-wide siren/message warning system, should it become necessary to notify neighboring residents of a plant emergency. Planned drills are used to test the procedures. Fortier also has mutual aid agreements with local agencies, which can assist in

the event of an emergency.



The Fortier Plant is constantly striving to upgrade its processes, control technology, employee training, and inspection, repair and maintenance of process equipment in order to improve safety.



TITLE V AIR PERMITS

Cornerstone currently has four Title V Operating Permits as follows:

Facility Permit I.D.

Acrylonitrile Plant 2195 (V-6)

Acid Plant 594 (V-4)

Melamine Plant 1981 (V-4)

Utilities Plant 2306 (V-4)



PROCESS HAZARD ANALYSIS (PHA) REVIEWS

The information submitted is true, accurate and complete as of January 26, 2017.