{"operation":"document","citation":"CPF 420097004W","title":"LOOP LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2009-10-29","effective_on":null,"summary":"CLOSED warning letter citing 195.132(a)(3), 195.569(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420097004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420097004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420097004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420097004W","body":"Warning Letter involving LOOP LLC. PHMSA's enforcement data identifies the cited regulations as 195.132(a)(3),  195.569(c). The case was opened on 2009-10-29 and is reported as closed as of 2009-10-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420097004W_Warning_10292009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420097004W/420097004W_Warning_10292009.pdf\n\n420097004W_Warning_10292009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420097004W/420097004W_Warning_10292009_text.pdf\n\n420097004W_Warning_10292009_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nOctober 29, 2009\nThomas L. Shaw\nPresident\nLouisiana Offshore Oil Port, LLC (LOOP)\n111 Veterans Memorial Blvd, Suite 600\nMetairie, LA 70005\nCPF 4-2009-7004W\nDear Mr. Thomas Shaw:\nOn November 17-21, 2008, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nLOOP pipeline system from the Marine Terminal to the Clovelly Salt Dome storage facility in\nGalliano, LA.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n\n\n\n1. §195.589 What corrosion control information do I have to maintain?\n(c) You must maintain a record of each analysis, check demonstration, examination,\ninspection, investigation, review, survey, and test required by this subpart in\nsufficient, detail to demonstrate the adequacy of corrosion control measures or that\ncorrosion requiring control measures does not exist. You must retain these records\nfor at least 5 years, except that records related to §§195.569, 195.573(a), and (b), and\n195.579(b)(3) and (c) must be retained for as long as the pipeline remains in service.\n§195.569 Do I have to examine exposed portions of buried pipelines?\nWhenever you have knowledge that any portion of a buried pipeline is exposed, you\nmust examine the exposed portion for evidence of external corrosion if the pipe is\nbare, or if the coating is deteriorated. If you find external corrosion requiring\ncorrective action under §195.585, you must investigate circumferentially and\nlongitudinally beyond the exposed portion (by visual examination, indirect method,\nor both) to determine whether additional corrosion requiring remedial action exists\nin the vicinity of the exposed portion.\nDuring the inspection, LOOP was requested to provide documentation to demonstrate that they\nare keeping records as required by §195.589(c), exposed pipe inspection reports. This office\nunderstands that in 2008, the Fourchon Booster Station Sump Tank was replaced with a new\nSump Tank and piping. The construction for the new tank exposed buried pipeline facilities, all\njurisdictional to PHMSA. To date this office has not been provided copies of these records.\n2. §195.132 Aboveground breakout tank.\n(a) Each aboveground breakout tank must be designed and constructed to\nwithstand the internal pressure produced by the hazardous liquid to be stored\ntherein and any anticipated external loads.\n(b) For aboveground breakout tank first placed in service after October 2, 2000,\ncompliance with paragraph (a) of this section requires one of the following:\n(3) Vertical, cylindrical, welded steel tanks with internal pressures at the\ntank top approximating atmospheric pressures (i.e., internal vapor space\npressures not greater than 2.5 psig (17.2 kPa), or not greater than the\npressure developed by the weight of the tank roof) must be designed and\nconstructed in accordance with API Standard 650.\nBreakout tanks 6402 and 6409 were inspected during the site visits. Both tanks were built to API\nStandard 650, 10th Edition. In API Standard 650, Welded Steel Tanks for Oil Storage, § 5.7.5\nShell Manholes, § 5.7.5.1 states “Shell manholes shall conform to Figures 5-7A and 5-7B and\nTables 5-3 through 5-5 (or Tables 5-6 through 5-8), but other shapes are permitted by 5.7.1.8.\nManhole reinforcing plates or each segment of the plates if they are not made in one piece shall\n2\n\n\n\nbe provided with a 6 mm (1/4 in.) diameter telltale hole (for detection of leakage through the\ninterior welds). Each hole shall be located on the horizontal centerline and shall be open to the\natmosphere.\nIt was noted during the inspection that the telltale holes were sealed with ¼ inch plugs and\ntherefore were not open to the atmosphere.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000\nfor each violation for each day the violation persists up to a maximum of $1,000,000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this letter.\nFailure to do so will result in Louisiana Offshore Oil Port, LLC being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2009-7004W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous\nMaterials Safety Administration\n3","truncated":false,"body_characters":5887}