# BELLE FOURCHE PIPELINE CO — Warning Letter

- **operation:** document
- **citation:** CPF 520145018W
- **title:** BELLE FOURCHE PIPELINE CO — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2014-11-21
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.402(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-520145018w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-520145018w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-520145018w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520145018W
**body:**

Warning Letter involving BELLE FOURCHE PIPELINE CO. 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.

Official case documents:

520145018W_warning letter_11212014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145018W/520145018W_warning%20letter_11212014.pdf

520145018W_warning letter_11212014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520145018W/520145018W_warning%20letter_11212014_text.pdf

520145018W_warning letter_11212014_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
November 21, 2014
Mr. H. A. “Tad” True
Vice President
Belle Fourche Pipeline Co.
455 N. Poplar St.
Casper, WY 82602
CPF 5-2014-5018W
Dear Mr. True:
During the week of August 20-24, 2012, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States
Code, inspected your Sussex Diesel Line in the Baker, Montana area.
As a result of the inspection, it appears that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and
the probable violation is:
1. §195.402 Procedural manual for operations, maintenance, and emergencies..
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and
maintenance activities and handling abnormal operations and emergencies.
This manual shall be reviewed at intervals not exceeding 15 months, but at least
once each calendar year, and appropriate changes made as necessary to insure
that the manual is effective. This manual shall be prepared before initial
operations of a pipeline system commence, and appropriate parts shall be kept
at locations where operations and maintenance activities are conducted.



The operator raised the Davis block valve from a below grade location to an above ground
location earlier in 2012. In doing this, it exposed part of the pipeline’s coating, external pipe
surface, and internal pipe surface. At the time of the inspection, there were no Exposed Pipe
Reports (PL-502) were available to document the condition of the pipeline. The operator’s
procedure requires completion of the Exposed Pipe Report PL-502 when the pipe is exposed
and the operator did not follow this procedure as required by §195.402(a).
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a
related series of violations. For violations occurring prior to January 4, 2012, the maximum
penalty may not exceed $100,000 per violation per day, with a maximum penalty not to
exceed $1,000,000 for a related series of violations. 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 items identified in this letter. Failure to do so will result in Belle Fourche Pipeline Co.
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 5-2014-5018W. 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 B. Brown (#140767)
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