# FRONT RANGE PIPELINE, LLC. — Warning Letter

- **operation:** document
- **citation:** CPF 520095037W
- **title:** FRONT RANGE PIPELINE, LLC. — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2009-10-16
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.583(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520095037w.json
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520095037w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520095037W
**body:**

Warning Letter involving FRONT RANGE PIPELINE, LLC.. PHMSA's enforcement data identifies the cited regulation as 195.583(a). The case was opened on 2009-10-16 and is reported as closed as of 2009-10-16. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520095037W_warning letter_10162009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095037W/520095037W_warning%20letter_10162009.pdf

520095037W_warning letter_10162009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095037W/520095037W_warning%20letter_10162009_text.pdf

520095037W_warning letter_10162009_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 16, 2009
Mr. John Traeger
Manager of Pipelines and Terminals
Front Range Pipeline, LLC
803 Highway 212 South
Laurel, MT 59044
CPF 5-2009-5037W
Dear Mr. Traeger:
On June 15-18, 2009, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected
your Front Range Pipeline from the Montana/Canada Border north of Cut Bank, Montana
to the Laurel Terminal in Laurel, Montana.
As a result of the inspection, it appears that Front Range Pipeline, LLC has committed a
probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal
Regulations. The item inspected and the probable violation is:
1. 195. 583 What must I do to monitor atmospheric corrosion control?
(a) You must inspect each pipeline or portion of pipeline that is exposed to the
atmosphere for evidence of atmospheric corrosion, as follows:
If the pipeline is located: Then the frequency of inspection is:
Onshore At least once every 3 calendar years, but
with intervals not exceeding 39 months
Offshore At least once each calendar year, but with
intervals not exceeding 15 months



(b) During inspections you must give particular attention to pipe at soil-to-air
interfaces, under thermal insulation, under disbonded coatings, at pipe
supports, in splash zones, at deck penetrations, and in spans over water.
(c) If you find atmospheric corrosion during an inspection, you must provide
protection against the corrosion as required by Sec. 195.581.
During the field inspection of the receiver barrel at the Raynesford Pump Station,
atmospheric corrosion was visible at the pipe and pipe support interfaces. In addition, it
did not appear that Front Range Pipeline had performed atmospheric corrosion evaluation
or mitigation activity at these pipe supports. Front Range Pipeline must periodically
inspect these pipe locations by temporarily lowering the pipe supports and checking for
coating damage and evidence of corrosion. If coating damage and/or evidence of corrosion
is observed, appropriate actions should be promptly taken to repair the coating damage
and/or corrosion.
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 5-2009-5037W. 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 M. Petronis (#123894)
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