{"operation":"document","citation":"CPF 420135003W","title":"LOOP LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-01-22","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a), 195.452(f)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420135003W","body":"Warning Letter involving LOOP LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.452(f)(4). The case was opened on 2013-01-22 and is reported as closed as of 2013-01-22. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420135003W_Operator Response to Notice_02222013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135003W/420135003W_Operator%20Response%20to%20Notice_02222013.pdf\n\n420135003W_Warning Letter_01222013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135003W/420135003W_Warning%20Letter_01222013.pdf\n\n420135003W_Warning Letter_01222013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135003W/420135003W_Warning%20Letter_01222013_text.pdf\n\n420135003W_Warning Letter_01222013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 22, 2013\nMr. Thomas Shaw\nPresident\nLOOP LLC\n137 Northpark Blvd.\nCovington, LA 70433\nCPF 4-2013-5003W\nDear Mr. Shaw:\nOn multiple occasions from August 20 through September 27, 2012, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of\n49 United States Code was onsite and inspected your LOOP Offshore Galliano pipeline unit in\nCut Off, 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 violation(s) are:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\nLOOP LLC did not follow its procedure S-000-HT-1 01 Pressure Testing of Pipelines, Piping\nSystems, and Aboveground Breakout Tanks Specification, Rev. 2 dated October 9, 2008, Section\n8.3-Documentation – Review, Approval, and Records. Section 8.3 requires “A pressure test is\n\n\n\nnot considered complete or accepted until all results are reviewed and approved by the LOOP\nIntegrity Management Coordinator. This includes all final documentation and reports.”\nLOOP LLC installed a drain pipe on a high pressure line before receiving and approving the\npressure test report for that piece of pipe, which was tested by a contractor.\n2. §195.452 Pipeline integrity management in high consequence areas.\nf. (4) Criteria for remedial actions to address integrity issues raised by the\nassessment methods and information analysis.\nLOOP LCC did not follow its procedure, Spec. No.: S-700-NE-101 Geometry Tool In-Line\nInspection Survey, Rev. 1 dated October 31, 2011.\nSec. 6.2, 6.3, and 6.4 require the contractor of the ILI Tool to provide a report of the tool’s\ntolerance validation to LOOP personnel. LOOP LLC did not validate the inspection tool\ntolerance in their anomalies analysis.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\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 LOOP LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2013-5003W. 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 Materials Safety Administration\n2","truncated":false,"body_characters":4874}