{"operation":"document","citation":"CPF 420145035W","title":"ENTERPRISE CRUDE PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-12-10","effective_on":null,"summary":"CLOSED warning letter citing 195.132(a), 195.132(b)(2), 195.132(b)(3), 195.132(b)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145035w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145035w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420145035w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420145035W","body":"Warning Letter involving ENTERPRISE CRUDE PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.132(a),  195.132(b)(2),  195.132(b)(3),  195.132(b)(4). The case was opened on 2014-12-10 and is reported as closed as of 2014-12-10. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420145035W_Warning_12102014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145035W/420145035W_Warning_12102014.pdf\n\n420145035W_Warning_12102014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420145035W/420145035W_Warning_12102014_text.pdf\n\n420145035W_Warning_12102014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 10, 2014\nMr. Kevin Bodenhamer\nSenior Vice President, Liquid Pipeline Operations\nEnterprise Crude Pipeline LLC\n1100 Louisiana Street\nHouston, TX 77002\nCPF 4-2014-5035W\nDear Mr. Bodenhamer:\nOn December 1-4, 2014; representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) inspected procedures, records and field construction on breakout tanks\nin Enterprise Crude Houston (ECHO) Terminal Houston, TX. On the basis of the inspection,\nPHMSA has identified apparent inadequacies found within Enterprise's construction practices, as\ndescribed below:\n1. 195.132 Aboveground breakout tank.\n(a) Each aboveground breakout tank must be designed and constructed to withstand the\ninternal pressure produced by the hazardous liquid to be stored therein and any\nanticipated 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: (1)\nShopfabricated, vertical, cylindrical, closed top, welded steel tanks with nominal\ncapacities of 90 to 750 barrels (14.3 to 119.2 m \\3\\) and with internal vapor space\npressures that are approximately atmospheric must be designed and constructed in\naccordance with API Specification 12F.\n(2) Welded, low-pressure (i.e., internal vapor space pressure not greater than 15 psig\n(103.4 kPa)), carbon steel tanks that have wall shapes that can be generated by a single\n\n\n\nvertical axis of revolution must be designed and constructed in accordance with API\nStandard 620.\n(3) Vertical, cylindrical, welded steel tanks with internal pressures at the tank top\napproximating atmospheric pressures (i.e., internal vapor space pressures not greater\nthan 2.5 psig (17.2 kPa), or not greater than the pressure developed by the weight of the\ntank roof) must be designed and constructed in accordance with API Standard 650.\n(4) High pressure steel tanks (i.e., internal gas or vapor space pressures greater than 15\npsig (103.4 kPa)) with a nominal capacity of 2000 gallons (7571 liters) or more of liquefied\npetroleum gas (LPG) must be designed and constructed in accordance with API\nStandard 2510.\nEnterprise failed to achieve compliance with API-650 Section 5.7.4.3 and its own Engineering\nStandards and Specifications, STD.5600 Section 5.7.4.1, by welding name plate bracket\nassemblies to thickened, post weld heat treated (PWHT) shell inserts after they were installed\ninto the shell of tanks 3901, 3902, 3903, 3904, 3905, and 3906. Small attachments are allowed\nto be welded to PWHT assemblies under API-650 Section 7.2.1.11, but the name plate\nassemblies were attached to the inserts by welding reinforcing plates that are approximately 4”\nwide by 8” long. These reinforcing plates do not fit the description of small attachments as\ndescribed in API-650 Section 7.2.1.11. By welding the name plate assemblies to the inserts after\nheat treatment the inserts can no longer be considered thermally stress relieved as an assembly\nprior to installation into the tank shell, which is required by the aforementioned standards.\nEnterprise must discontinue the practice of welding of large attachments to thickened, post weld\nheat treated (PWHT) shell inserts and abide by the requirements of Part 195, API-650 and its\nown Engineering Standards and Specifications.\n2. 195.132 Aboveground breakout tank.\n(a) Each aboveground breakout tank must be designed and constructed to withstand the\ninternal pressure produced by the hazardous liquid to be stored therein and any\nanticipated 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: (1)\nShopfabricated, vertical, cylindrical, closed top, welded steel tanks with nominal\ncapacities of 90 to 750 barrels (14.3 to 119.2 m \\3\\) and with internal vapor space\npressures that are approximately atmospheric must be designed and constructed in\naccordance with API Specification 12F.\n(2) Welded, low-pressure (i.e., internal vapor space pressure not greater than 15 psig\n(103.4 kPa)), carbon steel tanks that have wall shapes that can be generated by a single\nvertical axis of revolution must be designed and constructed in accordance with API\nStandard 620.\n(3) Vertical, cylindrical, welded steel tanks with internal pressures at the tank top\napproximating atmospheric pressures (i.e., internal vapor space pressures not greater\nthan 2.5 psig (17.2 kPa), or not greater than the pressure developed by the weight of the\ntank roof) must be designed and constructed in accordance with API Standard 650.\n(4) High pressure steel tanks (i.e., internal gas or vapor space pressures greater than 15\npsig (103.4 kPa)) with a nominal capacity of 2000 gallons (7571 liters) or more of liquefied\n\n\n\npetroleum gas (LPG) must be designed and constructed in accordance with API\nStandard 2510.\nEnterprise failed to provide reports of all nondestructive examinations (NDE) of tank shell\nattachments for tanks 3901, 3902, 3903, 3904, 3905 and 3906. API 650 Section 7.2.3.5 requires:\n“… The welds of permanent attachments (not including shell-to-bottom welds) and areas where\ntemporary attachments are removed, shall be examined visually and by either the magnetic\nparticle method or by the liquid penetrant method”. Furthermore, Appendix W.1.5 of the same\nstandard requires that the post-construction document package should contain reports of all\nNDE. The Operator provided an IRIS NDT Magnetic Particle report # 31390 which cited: “All\ntemporary attachments, + permanent attachments has been inspected and meet requirements of\nCode and Customer's request\"; however, reports of all NDE on tank shell attachments for tanks\n3901, 3902, 3903, 3904, 3905 and 3906 were not provided. Enterprise must provide reports of\nall NDE on tank shell attachments in order to abide with the requirements of API-650 and Part\n195.\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 take the required actions identified in this\nletter. Failure to do so will result in Enterprise Crude Pipeline 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 4-2014-5035W. 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\nEnclosures: Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":8251}