Document pYOBg7r5a47BQJ5rVMb8BpEE

fr'pnsvant'o ; ) C|MA4 A LOCATION) . F Havarrete - O-lOA DAT! March 15, 1982 UAJtCT tfltCNCI Out-of-Plant Pipeline Emergency Response TO G. L. Tromblee PMSB SAC has reviewed the existing procedure on Pipeline Emergency Response and the concerns and deficiencies identified by Plant Services. Our recommendation is: 1. A team approach, similar to that spelled out by the Transportation Accidents Procedure (P-0906), should be developed for Pipeline Emergencies. 2. Team membership should include: Key Person (with alternates) User Representative (depending on which pipeline) Industrial Hygiene) Environmental ) MMTS ) Public Relations ) On call as needed. 3. Key person should be part of the manufacturing services groups (either distribution or utilities)^and have routine as well as emergency res ponsibility for Texas City pipelines and rights of way. ;; - maintenance - taxes - revisions c- l3 - contact with Choc. Bayou and suppliers owning other pipelines in which T.C. may be called to respond in emergencies. This definition represents a realignment of responsibilities(that Plant Straff should~address-. . 4. Emergency Team should have appropriate equipment for response (possibly\ shared with transportation emergency team). 5. Key person should be assigned responsibility to develop Emergency Response Procedure, propose team membership, determine necessary equipment, set up training of team, etc. LAM026403 STG 2430271 SC 18740 G. L. Tromblee 2- - March 15, 1982 6. Responsibility for valves and keys required for pipeline control should be specified In the procedure. Background Pipelines entering or leaving the plant fall broadly in three categories. 1. Pipelines for which Texas City has unique responsibility: - Two raw water lines - NH3 line (two loops) from Dept. 10 to Dept. 19 - Two benzene lines from Coastal - Clarifier waste water line to N. 80 - 2 N2 lines to Grant Ave. tie-in with Big 3 - Waste water line to GCWDA - Propylene line from Amoco to Dept. 51 0*1 2. Chocolate Bayou to Texas^pipelines. Texas City has "first response" responsibility in emergencies on these lines this side of Hitchcock. 3. Supplier owned pipelines to the T.C. plant. Should respond and get involved in emergencies on these lines to assist and protect our interests. The following deficiencies have been identified on our current procedures: 1. MMTS corrosion inspector (singular) has assumed most of the pipeline responsibilities by default. These responsibilities more logically belong with operating groups. 2. The plant has too few people trained and familiar with pipelines, that may be convenient to report to the plant in emergencies. 3. Responsibilities do not logically fit with one single plant group as now organized and chartered. 4. Keys to locked valves on pipelines not easy to locate in emergencies. 5. Routine responsibilities f<#t pipeline revisions, maintenance, taxes, etc., not clearly defined. 6. Equipment (radio, transport, keys, etc.) not adequate to handle emergencies. C. F. Navarrete LAM026404 /ob Chairman, SAC STG 2430272 SC 18741