{"operation":"document","citation":"CPF 32026009NOA","title":"BRIDGER PIPELINE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2026-05-20","effective_on":null,"summary":"OPEN notice of amendment citing 195.446(c)(1), 195.446(c)(3), 195.446(c)(4), 195.446(e)(2), 195.446(e)(3), 195.446(g)(1), 195.446(j)(1).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32026009noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32026009noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32026009noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32026009NOA","body":"Notice of Amendment involving BRIDGER PIPELINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.446(c)(1),  195.446(c)(3),  195.446(c)(4),  195.446(e)(2),  195.446(e)(3),  195.446(g)(1),  195.446(j)(1). The case was opened on 2026-05-20 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32026009NOA_Notice of Amendment_05202026_(25-332208).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32026009NOA/32026009NOA_Notice%20of%20Amendment_05202026_(25-332208).pdf\n\n32026009NOA_Notice of Amendment_05202026_(25-332208)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32026009NOA/32026009NOA_Notice%20of%20Amendment_05202026_(25-332208)_text.pdf\n\n32026009NOA_Operator Response to Notice and Request for Time Extension (REDACTED)_06192026_(25-332208).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32026009NOA/32026009NOA_Operator%20Response%20to%20Notice%20and%20Request%20for%20Time%20Extension%20(REDACTED)_06192026_(25-332208).pdf\n\n32026009NOA_Notice of Amendment_05202026_(25-332208)_text.pdf\n\nU.S. Department of Transportation\nPipeline and Hazardous\nMaterials Safety Administration\n1100 Main Street, Suite 800\nKansas City, MO 64105\n(816) 329-3800\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: tad.true@truecos.com; Ken.Dockweiler@truecos.com;\nkevin.pena@truecos.com\nMay 20, 2026\nTad True\nChief Operating Officer\nBridger Pipeline, LLC\n455 North Poplar Street\nCasper, WY 82602\nCPF 3-2026-009-NOA\nDear Mr. True:\nFrom July 7, 2025, through July 25, 2025, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\nconducted an inspection of Bridger Pipeline, LLC (Bridger) procedures for its control room in\nCasper, Wyoming.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies within Bridger’s\ncontrol room management plans or procedures. The items inspected, alleged inadequacies, and\nproposed revisions are described below:\n1. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with\na controller working in a control room who monitors and controls all or\npart of a pipeline facility through a SCADA system. Each operator must\nhave and follow written control room management procedures that\nimplement the requirements of this section. . . .\n\n\n\n(b) . . . .\n(c) Provide adequate information. Each operator must provide its controllers\nwith the information, tools, processes and procedures necessary for the\ncontrollers to carry out the roles and responsibilities the operator has\ndefined by performing each of the following:\n(1) Implement API RP 1165 (incorporated by reference, see § 195.3)\nwhenever a SCADA system is added, expanded or replaced, unless\nthe operator demonstrates that certain provisions of API RP 1165\nare not practical for the SCADA system used;\nBridger’s Control Room Management (CRM) procedures were not adequate to provide its\ncontrollers with the information, tools, processes, and procedures necessary for the controllers to\ncarry out the roles and responsibilities the operator defined. Specifically, the CRM procedures did\nnot implement API RP 1165 for when a SCADA system is added, expanded, or replaced. API RP\n1165, section 5, states:\n5.3 DISPLAY RESPONSE\nDisplay sub-system response is a function of both hardware performance and\nsoftware design. In modern SCADA systems that use client server architecture,\nboth the host (server) and HMI computer (client) can affect the initial display call\nup time and data refresh rate. Once installed, display response times should be\nperiodically reviewed.\nBridger did not utilize an HMI style guide, nor define display call up time or data refresh rate by\ndesign in the CRM procedures. A process to review data refresh rates is not included in other\nsections of the CRM procedures or documentation. Per API RP 1165, section 5.3, display response\ntimes should be periodically reviewed.\nDisplay call up time and data refresh rate are an aspect of SCADA system performance, and a\ncritical part of the information, tools and processes needed for controllers to carry out roles and\nresponsibilities associated with abnormal operations. Without knowing how the SCADA system\nis to perform by design, implementing changes can degrade SCADA system performance. This\nchange in performance may go undetected, impacting information, tools and process necessary for\nthe controllers to carry out their roles and responsibilities. Knowing SCADA system performance\nand how to determine that the current system is performing as originally designed (or better) after\nimplementing a change (hardware or software related) is essential to prompt detection and\nresponse to abnormal operations. Abnormal operations, such as non-CPM leak detection systems\ngenerated alarms, detection of a cyber breach through the slowdown of processes or receiving\ninformation that a valve has been moved on an uncommand basis are all impacted by SCADA\nsystem performance display call up time and data refresh rate.\nBridger must amend its CRM procedures to include a periodic review of display call up time and\ndata refresh rate, whenever a SCADA system is added, expanded, or replaced, as required by\n§ 195.446(c)(1).\n2\n\n\n\n2. § 195.446 Control Room Management.\n(a) General. This section applies to each operator of a pipeline facility with\na controller working in a control room who monitors and controls all or\npart of a pipeline facility through a SCADA system. Each operator must\nhave and follow written control room management procedures that\nimplement the requirements of this section. . . .\n(b) . . . .\n(c) Provide adequate information. Each operator must provide its\ncontrollers with the information, tools, processes and procedures\nnecessary for the controllers to carry out the roles and responsibilities\nthe operator has defined by performing each of the following:\n(1) . . . .\n(3) Test and verify an internal communication plan to provide adequate\nmeans for manual operation of the pipeline safely, at least once each\ncalendar year, but at intervals not to exceed 15 months;\nBridger’s Control Room Management (CRM) procedures did not adequately implement the\nrequirements of internal communication plan testing and verification under § 195.446(c)(3). The\nCRM procedures in section 3.5, Internal Communication Plan (ICP), stated, “If adequate resources\nARE NOT available, steps will be taken to shut down the affected pipeline asset following safe\nshut down practices. Once a shutdown has been complete, the field personnel performing the\nshutdown shall communicate to the Control Room the task is complete.” When a pipeline is\nshutdown and not purged, the pipeline is still in operation.\nThe internal communication plan for manual operations does not adequately describe what will be\ndone to continue safe manual operations for the pipeline when it is shut down and not purged.\nThe CRM procedures or other referenced procedures must be amended to adequately describe\nwhat will be done to continue safe manual operations of the pipeline regardless of resource\navailability when shutdown must continue in manual operations.\n3. § 195.446 Control Room Management\n(a) General. This section applies to each operator of a pipeline facility with\na controller working in a control room who monitors and controls all or\npart of a pipeline facility through a SCADA system. Each operator must\nhave and follow written control room management procedures that\nimplement the requirements of this section.…\n(b) . . . .\n(c) Provide adequate information. Each operator must provide its\ncontrollers with the information, tools, processes and procedures\nnecessary for the controllers to carry out the roles and responsibilities\nthe operator has defined by performing each of the following:\n(1) . . . .\n3\n\n\n\n(4) Test any backup SCADA systems at least once each calendar year,\nbut at intervals not to exceed 15 months; and\nBridger’s Control Room Management (CRM) procedures were not adequate to effectuate testing\nany backup SCADA systems at least once each calendar year, but at intervals not to exceed 15\nmonths, as required by § 195.446(c)(4). The CRM procedures in section 3.9 referenced Appendix\nF: Backup Control Room Activation. Step 12 of Appendix F stated, \"Once back in the Primary\nControl Room, Controllers will immediately confirm that all normally used programs (SCADA\nand business network including POEMS and Outlook), and equipment are functional.\" These\nprocedures did not indicate what form, or documentation will be used to confirm proper\nfunctioning when returning to the Primary from the backup.\nIn addition, the seven steps currently identified in section 2.14 of the CRM procedures must be\nincluded in Appendix F to ensure proper implementation of the backup test.\nFurthermore, the procedures did not include documenting whether a server change was necessary\nwhen moving back to the Primary. This must be documented when testing any backup SCADA\nsystems. If an issue arises during the transfer back to the Primary, knowing whether a server change\nwas necessary may be required to return all functions to normal and end the test. CRM Form 302,\ncurrently used during backup testing, must also identify the duration of the backup test (start times\nand end times).\nBridger CRM procedures also require clarification on what record will be used to document a\ntransfer to the backup location due to an evacuation when an ICP is not activated for manual\noperation. The CRM procedures in section 2.14, Pipeline Control Room Evacuations, indicated\nthat the backup location would be used for any evacuation, planned or unplanned. However, there\nwas no reference to Form 302 being used should this actual event occur. The procedures must\nclarify what documentation would be used if an actual event occurred to confirm that the backup\nlocation is functioning properly.\n4. 195.446 Control room management\n(a) General. This section applies to each operator of a pipeline facility with\na controller working in a control room who monitors and controls all or\npart of a pipeline facility through a SCADA system. Each operator must\nhave and follow written control room management procedures that\nimplement the requirements of this section. . . .\n(b) . . . .\n(e) Alarm management. Each operator using a SCADA system must have a\nwritten alarm management plan to provide for effective controller\nresponse to alarms. An operator's plan must include provisions to:\n(1) . . . .\n(2) Identify at least once each calendar month points affecting safety\nthat have been taken off scan in the SCADA host, have had alarms\ninhibited, generated false alarms, or that have had forced or manual\n4\n\n\n\nvalues for periods of time exceeding that required for associated\nmaintenance or operating activities;\nBridger’s Control Room Management (CRM) procedures, section 5.9, Monthly SCADA Safety\nAlarms Reviews, were not adequate to identify at least once each calendar month points affecting\nsafety that have been taken off scan in the SCADA host, have had alarms inhibited, generated false\nalarms, or that have had forced or manual values for periods of time exceeding that required for\nassociated maintenance or operating activities, as required by § 195.446(e)(2). Specifically, the\nprocedures failed to include multiple sources of safety alarm data that must be included in the\nannual review. It also failed to describe how some of these sources of data were prepared. For\nexample,\n• Off-Scan – A spreadsheet (the Assistant Control Center Supervisor SCADA\nspreadsheet) was presented during the inspection. It was reported to have the off-\nscan points listed in this spreadsheet. However, how this spreadsheet was\nprepared and what conditions were included was not clear in the procedures. Off-\nscan also needs to include the Flowstate process that would be used to determine\nif points were not on-scan and the impact to the Flowstate leak detection segment.\nFor Flowstate, when a segment is offline, it is called suspended. This was not\nincluded in the monthly review.\n• Inhibited alarms – A spreadsheet (the Assistant Control Center Supervisor\nSCADA spreadsheet) was presented during the inspection. The alarm inhibit\nfeature is accomplished in a different way than the off-scan status, yet this was\nnot explained in the procedure (but was included in the same output file).\nSimilarly, Flowstate alarms could also be inhibited but they were not part of the\nmonthly review. PHMSA was also informed that this can be recorded on the PL\n913 and 501 forms. This needs to be added to the monthly review process. If any\nother type of alarm suspension or alarm shelving is used, this needs to be included\nas part of the monthly review process.\n• False alarms – False alarms include top activations, chattering alarms, fleeting\nalarms, and controller identified alarms with incorrect setpoints. False alarms can\nalso be found in PL 913 and 501 forms. For Flowstate, false alarms are\ndocumented in Alarm Log. POEMs also has information where controllers\ndocument False Alarm. There may be false alarms identified in the operating\nnotices or abnormal operations documentation as well. However, only a portion\nof these conditions were included in the monthly reviews.\n• Forced – A spreadsheet ( the Assistant Control Center Supervisor SCADA\nspreadsheet) was presented during the inspection. It was not clear how a forced\nvalue would be identified and placed in the spreadsheet. The current process and\nprocedures did not identify how a forced value occurring at the end device or the\nPLC would be determined. Flowstate does have a stale data alarm, and this can\nbe found in the alarm log; but it had not been incorporated into the monthly\n5\n\n\n\nreview. It was also not clear how loss of communication would be included in the\nmonthly alarm review.\n• Manual – During the inspection, manual modes and switching were discussed.\nWhile this was not typically done, data had not been reviewed for valves or pumps\nthat may have automatic/manual or local/remote, hand-off-auto, or position\nindicators available for review. This requires inclusion in the monthly alarm\nreview process.\nThe CRM procedure in section 5.9 requires amendment to include all relevant procedures, reports,\nand sources of data for various points’ status discussed above. It must also describe the process\nused to identify or prepare them.\nIn addition, during the discussion on the monthly alarm process, PHMSA identified several\ndefinitions used by Bridger that need to be clarified in the procedures or process documentation.\nStale Alarms need to be identified by the procedures as an alarm that takes longer than 24 hours\nto clear. Standing Alarms need to be defined as alarms that have not been cleared. Out-of-Service\nindication in SCADA needs clarified to indicate that the alarm will still come in to the controller.\n5. 195.446 Control room management\n(a) General. This section applies to each operator of a pipeline facility with\na controller working in a control room who monitors and controls all or\npart of a pipeline facility through a SCADA system. Each operator must\nhave and follow written control room management procedures that\nimplement the requirements of this section. . . .\n(b) . . . .\n(e) Alarm management. Each operator using a SCADA system must have a\nwritten alarm management plan to provide for effective controller\nresponse to alarms. An operator's plan must include provisions to:\n(1) . . . .\n(3) Verify the correct safety-related alarm set-point values and alarm\ndescriptions when associated field instruments are calibrated or\nchanged and at least once each calendar year, but at intervals not to\nexceed 15 months;\nBridger’s CRM procedures were not adequate to verify the correct safety-related alarm set-point\nvalues and alarm descriptions when associated field instruments are calibrated or changed at least\nonce each calendar year, but at intervals not to exceed 15 months, as required by § 195.446(e)(3).\nThe CRM procedure in sections 5.10 through 5.11 did not address how calibration of field\ninstruments, including that of pressure switches providing low pressure alarms, are verified to be\nthe correct values. The procedure must be amended to include calibration of field instruments.\n6\n\n\n\n6. 195.446 Control room management\n(a) General. This section applies to each operator of a pipeline facility with\na controller working in a control room who monitors and controls all or\npart of a pipeline facility through a SCADA system. Each operator must\nhave and follow written control room management procedures that\nimplement the requirements of this section. . . .\n(j) Compliance and deviations. An operator must maintain for review\nduring inspection:\n(1) Records that demonstrate compliance with the requirements of this\nsection.\nBridger’s CRM procedure was not adequate to ensure that records demonstrating compliance with\n§ 195.446(j)(1) were maintained. For example, § 195.446(e)(2) is the monthly alarm review\nprocess requirement. Identified deficiencies found during the monthly alarm review process need\nto result in a record that demonstrates how the deficiencies were addressed, per the requirement of\n§ 195.446(e)(6). Additionally, while the CRM plan in section 5.12, Controller Workload Review,\nindicated that steps will be made to address any deficiencies, it did not state that a record that will\ndemonstrate the deficiencies were addressed. Each of the different elements in § 195.446(e)(1)\nthrough (e)(5) must have a process resulting in a record to demonstrate that deficiencies were\naddressed to satisfy the requirements of § 195.446(j)(1). The CRM procedure must be amended to\naddress the lack of record generation.\n7. § 195.446 Control room management\n(a) General. This section applies to each operator of a pipeline facility with\na controller working in a control room who monitors and controls all or\npart of a pipeline facility through a SCADA system. Each operator must\nhave and follow written control room management procedures that\nimplement the requirements of this section. . . .\n(b) . . . .\n(g) Operating experience. Each operator must assure that lessons learned\nfrom its operating experience are incorporated, as appropriate, into its\ncontrol room management procedures by performing each of the\nfollowing:\n(1) Review accidents that must be reported pursuant to § 195.50 and\n195.52 to determine if control room actions contributed to the event\nand, if so, correct, where necessary, deficiencies related to:\n(i) Controller fatigue;\n(ii) Field equipment;\n(iii) The operation of any relief device;\n(iv) Procedures;\n(v) SCADA system configuration; and\n(vi) SCADA system performance.\n7\n\n\n\nBridger’s CRM procedures were not adequate to ensure that lessons learned from its operating\nexperience are incorporated, as appropriate, into its CRM procedures. Specifically, the procedures\nfailed to identify how each of the required conditions under (g)(1) would be reviewed for a\ndeficiencies and corrections.\nThe procedures did not define what would be reviewed for accidents to determine if the control\nroom actions contributed to the event, such as the alarm and event log. The procedures did not\ndefine how a deficiency in controller fatigue, field equipment, the operation of any relief device,\nprocedures, SCADA system configuration and SCADA system performance would be found or\ndetermined to exist.\nIn addition, Section 7 of the CRM procedures referred to the Operations and Maintenance Manual\nSection 7.7 Emergency Procedures. Section 7.7 was called Post Accident Review and references\n49 CFR § 195.402(e)(9). Section 7.7 stated a post-accident review shall commence within 45 days\nof an accident no longer being classified as an emergency event. It was not clear in procedures\nwhat would cause an event to be considered no longer an emergency.\nThe procedures must be amended to ensure that lessons learned from its operating experience are\nincorporated, as appropriate, into its control room management procedures and all aspects of §\n195.446 (g)(1) are reviewed.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part\nof this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you submit\nin response to this enforcement action is subject to being made publicly available. If you believe\nthat any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. §\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting this Notice,\nwe propose that you submit your amended procedures to my office within 30 days of receipt of\n8\n\n\n\nthis Notice. This period may be extended by written request for good cause. Once the inadequacies\nidentified herein have been addressed in your amended procedures, this enforcement action will\nbe closed.\nIt is requested (not mandated) that Bridger Pipeline, LLC maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to the Director, Central Region, Pipeline and Hazardous\nMaterials Safety Administration, Office of Pipeline Safety. In correspondence concerning this\nmatter, please refer to CPF 3-2026-009-NOA and, for each document you submit, please provide\na copy in electronic format whenever possible.\nSincerely,\nAJ McKean\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\ncc: Ken Dockweiler, Director Government and Control Center, ken.dockweiler@truecos.com\nKevin Pena, Pipeline Compliance Coordinator, kevin.pena@truecos.com\n9","truncated":false,"body_characters":22872}