# FRONT RANGE PIPELINE, LLC. — Warning Letter

- **operation:** document
- **citation:** CPF 520085032W
- **title:** FRONT RANGE PIPELINE, LLC. — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2008-09-15
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.432(b).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520085032w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520085032W
**body:**

Warning Letter involving FRONT RANGE PIPELINE, LLC.. PHMSA's enforcement data identifies the cited regulation as 195.432(b). The case was opened on 2008-09-15 and is reported as closed as of 2008-09-15. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520085032W_warning letter_09152008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520085032W/520085032W_warning%20letter_09152008.pdf

520085032W_warning letter_09152008.pdf

u.s. Department 12300 W. Dakota Ave., Suite 110
of Transportation Lakewood, CO 80228
Pipeline and
Hazardous MaterialS Safety
Administration
WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 15, 2008
Mr. John Traeger
Manager of Pipelines and Terminals
Front Range Pipeline, LLC
803 Highway 212 South
Laurel, MT 59044
CPF 5-2008-5032W
Dear Mr. Traeger:
On June 10, 2008, a representative ofthe Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
breakout tanks in Laurel, Montana.
As a result ofthe inspection, it appears that Front Range Pipeline, LLC, has committed a
probable violation ofthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations.
The items inspected and the probable violation is:
1. §195.432 Breakout tanks.
(b) Each operator shall inspect the physical integrity of in-service atmospheric and
low-pressure steel aboveground breakout tanks according to section 4 of API
Standard 653. However, if structural conditions prevent access to the tank bottom,
the bottom integrity may be assessed according to a plan included in the operations
and maintenance manual under §195.402(c)(3).



Front Range Pipeline, LLC, did not externally inspect all of its breakout tanks at the
required time interval. API Standard 653 Section 4.3.2, External Inspection, requires
tanks to receive an external inspection by an Authorized Inspector at least once every 5
years. Using this guidance, Tank 95 should have received an external inspection by an
Authorized Inspector in August 2007. At the time ofthis PHMSA inspection, no external
inspection by an Authorized Inspector had been completed.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000
for each violation for each day the violation persists up to a maximum of $1 ,000,000 for any
related series of violation. 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 item identified in this letter.
Failure to do so will result in Front Range Pipeline, LLC 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 5-2008-5032W. 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).
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 G. Davis (#121993)
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