# FRONT RANGE PIPELINE, LLC. — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 520095039
- **title:** FRONT RANGE PIPELINE, LLC. — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2009-11-10
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.116(e), 195.126, 195.573(a)(2).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520095039.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520095039.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520095039
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520095039
**body:**

Notice of Probable Violation involving FRONT RANGE PIPELINE, LLC.. PHMSA's enforcement data identifies the cited regulations as 195.116(e),  195.126,  195.573(a)(2). The case was opened on 2009-11-10 and is reported as closed as of 2014-03-04. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520095039_closure letter_03042014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095039/520095039_closure%20letter_03042014.pdf

520095039_closure letter_03042014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095039/520095039_closure%20letter_03042014_text.pdf

520095039_FinalOrder_03012010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095039/520095039_FinalOrder_03012010.pdf

520095039_FinalOrder_03012010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095039/520095039_FinalOrder_03012010_text.pdf

520095039_NOPV letter_11102009.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095039/520095039_NOPV%20letter_11102009.pdf

520095039_NOPV letter_11102009_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520095039/520095039_NOPV%20letter_11102009_text.pdf

520095039_closure letter_03042014_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 4, 2014
Mr. John Traeger
President
Front Range Pipeline, LLC
P.O. Box 909
Laurel, MT 59044-0909
RE: CPF 5-2009-5039
Case Closure
Dear Mr. Traeger:
On March 1, 2010, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Front Range Pipeline, LLC a Final Order in the above-referenced case. This Final
Order included a Compliance Order which mandated the completion of a Close Interval Survey
(CIS) of your Front Range Pipeline System. The data from that survey was received by you on
December 20, 2013, and reviewed by my staff on February 20, 2014. Based on our review of the
documentation, it has been determined that you have complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Chris Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 M. Petronis (#123894)

520095039_FinalOrder_03012010_text.pdf

MAR 1 2010
Mr. Daniel Knepper
President and Chief Operating Officer
Front Range Pipeline, LLC
803 Highway 212 South
P.O. Box 909
Laurel, MT 59044
Re: CPF No. 5-2009-5039
Dear Mr. Knepper:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation and specifies actions that need to be taken by Front Range Pipeline, LLC, to comply
with the pipeline safety regulations. When the terms of the compliance order have been
completed, as determined by the Director, Western Region, this enforcement action will be
closed. Service of the Final Order by certified mail is deemed effective upon the date of mailing,
or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Chris Hoidal, Director, Western Region, OPS
Mr. John Traeger, Manager, Pipelines and Terminals, Front Range Pipeline, LLC
CERTIFIED MAIL – RETURN RECEIPT REQUESTED [7009 1410 0000 2472 5040]



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
______________________________
)
In the Matter of )
)
Front Range Pipeline, LLC, ) CPF No. 5-2009-5039
)
Respondent. )
______________________________)
FINAL ORDER
On June 15 to 18, 2009, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),
conducted an on-site pipeline safety inspection of the facilities and records of Front Range
Pipeline, LLC (Front Range or Respondent), in Montana. Front Range is the operator of a
hazardous liquid pipeline system that originates at the Canadian border and runs through the
cities of Cut Bank and Laurel, Montana.
As a result of the inspection, the Director, Western Region, OPS (Director), issued to
Respondent, by letter dated November 10, 2009, a Notice of Probable Violation and Proposed
Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed
finding that Front Range had committed various violations of 49 C.F.R. Part 195 and proposed
ordering Respondent to take certain measures to correct the alleged violations.
Front Range responded to the Notice by letter dated January 7, 2010 (Response). Respondent
did not contest the allegations of violation. Front Range did not request a hearing and therefore
has waived its right to one.
FINDINGS OF VIOLATION
In its Response, Front Range did not contest the allegations in the Notice that it violated 49
C.F.R. Part 195, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R.
§ 195.116, which states in relevant part:



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§ 195.116 Valves.
following:
Each valve installed in a pipeline system must comply with the
(a) . . . .
(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.).
In particular, the Notice alleged that Front Range violated § 195.116(e) because the positions of
two valves at the Raynesford Pump Station, Valve #FR59 and Valve #FR63, were not clearly
indicated at the time of the OPS inspection. Respondent did not contest this allegation of
violation. Accordingly, based upon a review of all of the evidence, I find that Respondent
violated 49 C.F.R. § 195.116(e) by failing to clearly indicate the positions of Valve #FR59 and
Valve #FR63 at the time of the OPS inspection.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.126, which states:
§ 195.126 Flange connection.
Each component of a flange connection must be compatible with
each other component and the connection as a unit must be suitable for the
service in which it is to be used.
The Notice alleged that Front Range violated § 195.126 because many of the studs on the flange
connections of Valve #FR45A and Valve #FR45D at the Conrad Pump Station were not of
sufficient length to allow the nuts to be fully threaded at the time of the OPS inspection.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.126 by failing to ensure that
each component of the flange connections at the Conrad Pump Station were compatible with
each other component and that these connections as a unit were suitable for their intended use in
service.
Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.573, which states, in
relevant part:
§ 195.573 What must I do to monitor external corrosion control?
(a) Protected pipelines. You must do the following to determine
whether cathodic protection required by this subpart complies with
§ 195.571:
(1) . . . .
(2) Identify not more than 2 years after cathodic protection is installed, the
circumstances in which a close-interval survey or comparable technology is practicable
and necessary to accomplish the objectives of paragraph 10.1.1.3 of NACE Standard RP
0169 (incorporated by reference, see § 195.3).
The Notice alleged that Front Range violated § 195.573(a)(2) by failing to perform a close-
interval (or comparable technological) survey or an analysis showing why such a survey was not
necessary at the time of the OPS inspection. Respondent did not contest this allegation of
violation. Accordingly, based upon a review of all of the evidence, I find that Respondent



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violated 49 C.F.R. § 195.573(a)(2) by failing to perform a close-interval survey (or a comparable
technological survey) or an analysis showing why such a survey was unnecessary.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1, 2 and 3 in the Notice for
violations of 49 C.F.R. §§ 195.116(e), 195.126, and 195.573(a)(2), respectively. Under 49
U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who
owns or operates a pipeline facility is required to comply with the applicable safety standards
established under chapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R.
§ 190.217, Respondent is ordered to take the following actions to ensure compliance with the
pipeline safety regulations applicable to its operations:
1. With respect to Item 1 of the Notice pertaining to Valve #FR59 and Valve
#FR63 at the Raynesford Pump Station, Front Range must install a means
for clearly indicating the position of each of these valves.
2. With respect to Item 2 of the Notice pertaining to the flanged connections
of Valve #FR45A (MOV) and Valve #FR45D at the Conrad Pump Station,
Front Range must install studs of a sufficient length in each of the flanged
connections to ensure that the full strength of the ANSI 600 flanges is
obtained.
3. With respect to Item 3 of the Notice pertaining to the cathodic protection
program, Front Range must conduct a close-interval survey along the
entire length of the pipeline, or perform and document an analysis
determining why a close interval survey is not necessary along the entire
length of the pipeline or certain segments of the pipeline.
4. Front Range shall maintain documentation of the safety improvement
costs associated with fulfilling this compliance Order and submit the total
to Christopher Hoidal, Director, Western Region, Pipeline and Hazardous
Materials Safety Administration. Costs shall be reported in two categories:
1) total cost associated with preparation/revision of plans, procedures,
studies and analyses, and 2) total cost associated with replacements,
additions and other changes to pipeline infrastructure.
5. Front Range must complete each of these actions within 180 days of the
date of this Order.



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The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $100,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.
Under 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline
Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC
20590. A copy of the petition should also be sent to: Assistant Chief Counsel for Pipeline
Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC
20590. The petition must be received no later than 20 days after service of this Final Order upon
the Respondent and must contain a brief statement of the issue(s) and meet all other requirements
of 49 C.F.R. § 190.215. Unless the Associate Administrator, upon request, grants a stay, the
terms and conditions of this Final Order are effective upon receipt of service.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety
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