{"operation":"document","citation":"CPF 520155001W","title":"FRONT RANGE PIPELINE, LLC. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-01-15","effective_on":null,"summary":"CLOSED warning letter citing 195.428(a), 195.573(a)(1), 195.573(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520155001W","body":"Warning Letter involving FRONT RANGE PIPELINE, LLC.. PHMSA's enforcement data identifies the cited regulations as 195.428(a),  195.573(a)(1),  195.573(e). The case was opened on 2015-01-15 and is reported as closed as of 2015-01-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520155001W_Warning Letter_01152015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155001W/520155001W_Warning%20Letter_01152015.pdf\n\n520155001W_Warning Letter_01152015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155001W/520155001W_Warning%20Letter_01152015_text.pdf\n\n520155001W_Warning Letter_01152015_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 15, 2015\nMr. John Traeger\nPresident\nFront Range Pipeline, LLC\nP.O. Box 909\nLaurel, MT 59044-0909\nCPF 5-2015-5001W\nDear Mr. Traeger:\nDuring the week of June 9, 2014, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 CFR United States Code,\ninspected the Front Range Pipeline facilities from the US/Canada border to the Santa Rita\nPump Station located near Cut Bank, Montana and related operation and maintenance\nrecords at the Front Range Pipeline office in Laurel, Montana.\nAs a result of the inspections, it appears that Front Range Pipeline, LLC has committed\nprobable violations of the Pipeline Safety Regulations, Title 49, Code of Federal\nRegulations. The items inspected and the probable violations are:\n1. §195.428(a) Overpressure safety devices and overfill protection systems\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in\nthe case of pipelines used to carry highly volatile liquids, at intervals not to\nexceed 7 ½ months, but at least twice each calendar year, inspect and test each\npressure limiting device, relief valve, pressure regulator, or other item of\npressure control equipment to determine that it is functioning properly, is in\n\n\n\ngood mechanical condition, and is adequate from the standpoint of capacity\nand reliability of operation for the service in which it is used\nAt the time of the inspection, Front Range Pipeline did not have an overpressure protection\nsafety device installed on the pipelines coming in to the Santa Rita Station from Canada.\nFront Range indicated that they rely upon the operator of the pipelines in Canada to\nprovide and test overpressure safety devices on the pipelines located in Canada to prevent\nthe portion of the pipelines that Front Range owns and operates in the US from exceeding\nthe allowable maximum operating pressure (MOP) of the pipe. This is not an acceptable\nmethodology to ensure the MOP of the pipelines is not exceeded. As of November 2014,\nFront Range indicated that it ordered overpressure safety devices for the pipelines and\nplanned to install them at the Santa Rita Station by the end of 2014.\nFront Range must ensure that each of the pipelines crossing the border from Canada that it\nowns and operates has overpressure safety devices installed in the United States to prevent\nthe MOP of the pipelines from being exceeded and that each of these devices are inspected\nand tested in accordance with the requirements of 195.428.\n2. §195.573 What must I do to monitor external corrosion control?\n(a) Protected pipelines. You must do the following to determine whether\ncathodic protection required by this subpart complies with §195.571:\n(1) Conduct tests on the protected pipeline at least once each calendar year,\nbut with intervals not exceeding 15 months. However, if tests at those intervals\nare impractical for separately protected short sections of bare or ineffectively\ncoated pipelines, testing may be done at least once every 3 calendar years, but\nwith intervals not exceeding 39 months.\nA Close Interval Survey (CIS) was completed on the Front Range pipelines in May 2011.\nThe CIS data indicates that some areas exist (1.21% on the 16\" line and 4.49% on the 6\"\nline) that do not meet the -850mV off cathodic protection criteria. Front Range personnel\nindicated that it has assigned a team to develop a CIS Response Plan which is scheduled to\nbe completed by the end of 2014.\nFront Range must ensure that the entire length of each pipeline that comprises the Front\nRange Pipeline System meets the required minimum cathodic protection levels.\n3. §195.573 What must I do to monitor external corrosion control?\n(e) Corrective action. You must correct any identified deficiency in corrosion\ncontrol as required by §195.401(b). However, if the deficiency involves a\npipeline in an integrity management program under §195.452, you must\ncorrect the deficiency as required by §195.452(h).\n2\n\n\n\nA Close Interval Survey (CIS) was completed on the Front Range pipelines in May 2011.\nThe CIS data indicates that some areas exist (1.21% on the 16\" line and 4.49% on the 6\"\nline) that do not meet the -850mV off cathodic protection criteria. Front Range personnel\nindicated that it has assigned a team to develop a CIS Response Plan which is scheduled to\nbe completed by the end of 2014.\nFront Range must ensure that the entire length of each pipeline that comprises the Front\nRange Pipeline System meets the required minimum cathodic protection levels.\nFurthermore, whenever Front Range discovers any condition that could adversely affect\nthe safe operation of its pipeline system, it must correct the condition within a reasonable\ntime.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of\n$1,000,000 for any related series of violation. We have reviewed the circumstances and\nsupporting 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\ncorrect the items identified in this letter. Failure to do so will result in Front Range\nPipeline, LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please\nrefer to CPF 5-2015-5001W. 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\ntreatment under 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 M. Petronis (#145449)\n3","truncated":false,"body_characters":6931}