# BELLE FOURCHE PIPELINE CO — Warning Letter

**Citation:** CPF 520145002W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2014-02-19

CLOSED warning letter citing 195.116(e), 195.204, 195.422(a).

## Document text

Warning Letter involving BELLE FOURCHE PIPELINE CO. PHMSA's enforcement data identifies the cited regulations as 195.116(e),  195.204,  195.422(a). The case was opened on 2014-02-19 and is reported as closed as of 2014-02-19. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520145002W_warning letter_02192014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145002W/520145002W_warning%20letter_02192014.pdf

520145002W_warning letter_02192014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145002W/520145002W_warning%20letter_02192014_text.pdf

520145002W_warning letter_02192014_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
February 19, 2014
Mr. Tad True
Vice President
Belle Fourche Pipeline Company
455 N Poplar St.
Casper, WY 82602
CPF 5-2014-5002W
Dear Mr. True:
Between November 14, 2011 and March 9, 2012, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
investigated a November 14, 2011 release from your Sussex Diesel Pipeline System’s Davis
Station southwest of Gillette, Wyoming. The release spilled 1900 barrels of diesel into the
ground, causing soil contamination.
As a result of the investigation, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violation(s) are:
1. §195.116(e) Valves.
(e) Each valve other than a check valve must be equipped with a means for clearly
indicating the position of the valve (open, closed, etc.).



One of the mainline valves at the Davis Station was not equipped with a means for clearly
indicating the position of the valve. All three of the mainline valves at the Davis Station were
housed in a below-ground steel vault. Two of the three valves – the tank inlet and the tank
outlet– had valve extensions that came above-ground to enable employees to operate these two
valves without entering the valve vault. However, there was no extension on the third mainline
valve to indicate the valve’s position.
According to interviews with your staff, Belle Fourche Pipeline Company (BFPL’s) normal
operating practice was to keep this mainline valve open at all times because of the elevation
profile of this line. Since there was no above-ground indicator showing the valve’s position as
closed, BFPL employees incorrectly believed that the valve was open prior to the pipeline
startup. However, at the time of the pipeline failure, the mainline valve was closed. As a result,
the controller pumped against closed valves resulting in failure of the valve flange gasket and the
release of 1900 barrels of diesel.
2. §195.204 Inspection - General.
Inspection must be provided to ensure the installation of pipe or pipeline systems in
accordance with the requirements of this subpart. No person may be used to
perform inspections unless that person has been trained and is qualified in the phase
of construction to be inspected.
BFPL did not perform the required inspection of the pipeline installation that failed. BFPL could
not confirm that the 4” flanged valve that failed had been inspected by a person trained and
qualified to inspect the installation of a flanged valve. During the investigation, BFPL
employees who performed the 2008 repair of the Davis mainline valve were interviewed. When
asked who was in charge of inspecting the valve repair and flange gasket installation, each said
that they remembered doing the job but nobody interviewed could remember who was in charge
of inspecting the valve and valve installation. BFPL had no records regarding the 2008
installation of the new Davis mainline valve.
3. §195.422(a) Pipeline Repairs.
(a) Each operator shall, in repairing its pipeline systems, insure that the repairs are
made in a safe manner and are made so as to prevent damage to persons or
property.
2



BFPL documents show that the Davis mainline valve was replaced in 2008. An examination of
the flange gasket after the release shows a portion of the flange did not have an indentation from
the flange face. This lack of an indention on the gasket indicates that not all of the flange bolts
were properly torqued, and thus the flange seal was not properly completed. This failure to
properly install the flange contributed to the pipeline release. BFPL did not insure that the repair
of the pipeline (by installing a new mainline valve) was made in a safe manner and was made so
as to prevent damage to persons or property.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000
per violation per day the violation persists up to a maximum of $2,000,000 for a related series of
violations. For violations occurring prior to January 4, 2012, the maximum penalty may not
exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a
related series of violations. We understand that the valves and flanges at the Davis Station have
been brought above ground, properly installed, inspected, have position indicators, and are
enhance with operational instruction signs. We have reviewed the circumstances and supporting
documents involved in this case, and have decided not to conduct additional enforcement action
or penalty assessment proceedings at this time. We advise you to correct the items identified in
this letter. Failure to do so will result in Belle Fourche being subject to additional enforcement
action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to
CPF 5-2014-5002W. Be advised that all material you submit in response to this enforcement
action is subject to being made publicly available. If you believe that any portion of your
responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the
complete original document you must provide a second copy of the document with the portions
you believe qualify for confidential treatment redacted and an explanation of why you believe
the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 P. Katchmar (#136756)
3

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520145002W>
- Source ID: `phmsa-enforcement`
- SHA-256: `a9f9c9621389ab52b2ae301b8d12dfc232234d595c871579e7b726e8ba675a6f`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-24T09:36:56.857Z
- Document slug: `phmsa-enforcement-520145002w`

### Source metadata

```json
{
  "cpf": "520145002W",
  "operator": "BELLE FOURCHE PIPELINE CO",
  "region": "Western",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.116(e)",
    "195.204",
    "195.422(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
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      "bytes": 66431,
      "category": "agency_document"
    },
    {
      "name": "520145002W_warning letter_02192014_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520145002W/520145002W_warning%20letter_02192014_text.pdf",
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  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "BELLE FOURCHE PIPELINE CO"
}
```
