{"operation":"document","citation":"CPF 520145017W","title":"BRIDGER PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-11-21","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520145017w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520145017w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520145017w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520145017W","body":"Warning Letter involving BRIDGER PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.402(a). The case was opened on 2014-11-21 and is reported as closed as of 2014-11-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520145017W_warning letter_11212014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145017W/520145017W_warning%20letter_11212014.pdf\n\n520145017W_warning letter_11212014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145017W/520145017W_warning%20letter_11212014_text.pdf\n\n520145017W_warning letter_11212014_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 21, 2014\nMr. H. A. “Tad” True\nVice President\nBridger Pipeline LLC\n455 N Poplar St.\nCasper, WY 82602\nCPF 5-2014-5017W\nDear Mr. True:\nDuring the week of May 21-25, 2012, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States\nCode, inspected your Poplar Pipeline system in the Glendive, Montana area.\nAs a result of the inspection, it appears that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and\nthe probable violation is:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies..\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and\nmaintenance activities and handling abnormal operations and emergencies.\nThis manual shall be reviewed at intervals not exceeding 15 months, but at least\nonce each calendar year, and appropriate changes made as necessary to insure\nthat the manual is effective. This manual shall be prepared before initial\n\n\n\noperations of a pipeline system commence, and appropriate parts shall be kept\nat locations where operations and maintenance activities are conducted.\nBridger Pipeline staff did not follow their written procedures for conducting normal\noperations and maintenance activities, specifically your procedures to examine exposed pipe\nper §195.569. Bridger Pipeline conducted 24 In-line inspection verification digs (February 15\n– March 20, 2012) on the Poplar Pipeline. All 24 digs were for external anomalies. We\nunderstand that since none of the coating was removed, the external and internal condition of\nthe pipe’s metallic surface were not noted. Nevertheless, the pipe coating was exposed and\nthe condition of the coating and the date of the exposures were not noted on the operator’s\nform PL-502. The operator’s procedure requires completion of the exposed pipe report PL-\n502 when the pipe is exposed and the operator did not follow this procedure as required by\n§195.402(a).\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a\nrelated series of violations. For violations occurring prior to January 4, 2012, the maximum\npenalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct\nthe items identified in this letter. Failure to do so will result in Bridger Pipeline LLC being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2014-5017W. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any\nportion 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\nunder 5 U.S.C. 552(b).\nSincerely,\nChris Hoidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 B. Brown (#138067)\n2","truncated":false,"body_characters":4389}