{"operation":"document","citation":"CPF 520155003H","title":"BRIDGER PIPELINE LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2015-01-23","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155003h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155003h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520155003h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520155003H","body":"Corrective Action Order involving BRIDGER PIPELINE LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2015-01-23 and is reported as closed as of 2017-12-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520155003H_Closure Letter_12042017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155003H/520155003H_Closure%20Letter_12042017.pdf\n\n520155003H_Closure Letter_12042017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155003H/520155003H_Closure%20Letter_12042017_text.pdf\n\n520155003H_Corrective Action Order_01232015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155003H/520155003H_Corrective%20Action%20Order_01232015.pdf\n\n520155003H_Corrective Action Order_01232015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520155003H/520155003H_Corrective%20Action%20Order_01232015_text.pdf\n\n520155003H_Closure Letter_12042017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 4, 2017\nMr. Tad True\nPresident\nBridger Pipeline LLC\nP.O. Drawer 2360\nCasper, WY 82602\nCPF 5-2015-5003H\nClosure Letter\nDear Mr. True:\nOn January 23, 2015, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Bridger Pipeline LLC a Corrective Action Order in the above-referenced case. This\nOrder requires Bridger Pipeline LLC to take certain corrective measures with respect to the\nPoplar Pipeline system that failed on January 17, 2015, near Glendive, Montana. Based on\nour review of the documentation you provided, it has been determined that you have complied\nwith all the terms of the Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nKim West\nActing Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 H. Nguyen\n\n520155003H_Corrective Action Order_01232015_text.pdf\n\nJanuary 23, 2015\nVIA CERTIFIED MAIL AND FAX TO: 307-237-3164\nMr. Tad True\nPresident\nBridger Pipeline, LLC\n455 N. Poplar St.\nP.O. Drawer 2360\nCasper, WY 82602\nRe: CPF No. 5-2015-5003H\nDear Mr. True:\nEnclosed is a Corrective Action Order issued today in the above-referenced case. It requires\nBridger Pipeline, LLC, to take certain corrective actions with respect to the Poplar Pipeline\nsystem that failed on January 17, 2015, near Glendive, Montana. Service is being made by\ncertified mail and facsimile. Service of the Corrective Action Order by electronic transmission is\ndeemed complete upon transmission and acknowledgement of receipt, or as otherwise provided\nunder 49 C.F.R. § 190.5. The terms and conditions of this Order are effective upon completion\nof service.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Chris Hoidal, Director, Western Region, OPS\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nBridger Pipeline, LLC, ) CPF No. 5-2015-5003H\n)\n)\n)\nRespondent. )\n____________________________________)\nCORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Corrective Action Order (Order) is being issued, under the authority of 49 U.S.C. § 60112,\nto require Bridger Pipeline, LLC (Bridger or Respondent), to take necessary corrective action to\nprotect the public, property, and the environment from potential hazards associated with the\nrecent failure on Bridger’s Poplar Pipeline system.\nOn January 17, 2015, a reportable accident occurred on the Poplar Pipeline, resulting in the\nrelease of approximately 300-1200 barrels of crude oil (the Failure). The Poplar Pipeline is a 10-\nand 12-inch diameter pipeline approximately 193 miles in length that transports crude oil from\nthe Raymond meter station in Sheridan County, Montana, to the Baker station in Fallon County,\nMontana (Poplar Pipeline or Affected Pipeline). The cause of the Failure has not yet been\ndetermined. Pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of the\naccident. The preliminary findings of the ongoing investigation are as follows:\nPreliminary Findings:\n• Bridger is one of a group of companies known generally as the True Companies. Bridger\nowns and operates the Poplar Pipeline System in eastern Montana, the Four Bears\nPipeline System in North Dakota, the Parshall gathering system in North Dakota, and the\nPowder River gathering system in Wyoming.1\n• Bridger has indicated that the Poplar Pipeline (Affected Pipeline) is composed of the\nfollowing segments:\n1 http://truecompanies.truecos.com/Bridger/, last accessed January 22, 2015.\n\n\n\nCPF No: 5-2015-5003H\nPage 2\no The pipeline segment between Raymond station and Poplar station, which\nconsists of 56, miles of 12-inch, X-52, 0.188-inch wall thickness, electric\nresistance welded (ERW) pipe, installed in 1972.\no The pipeline segment between Poplar station and Glendive station consists of 84\nmiles of 10-inch, X-46, mostly 0.250-inch wall thickness, ERW pipe, installed in\n1955. In 2005, six miles of pipe were replaced between Poplar station and\nGlendive station. This pipeline segment crosses the Missouri River and was\ninstalled by horizontal directional drilling (HDD). This pipeline segment also\ncrosses the Poplar River and was installed using an open-cut river crossing.\no The pipeline segment between Glendive station and Baker station consists of 53\nmiles of 12-inch, X-52, mostly 0.250-inch wall thickness, ERW pipe, installed in\n1955. In 1967, 2250 feet of this pipe was replaced with 12-inch nominal\ndiameter, X52, 0.500-inch wall thickness pipe manufactured by National Tube.\nThis portion of the pipeline crosses the Yellowstone River. The 1967 river\ncrossing was made using an open-cut method: a trench was excavated in the\nbottom of the river channel, the pipeline was laid in the open cut, and the trench\nthen filled with backfill from the excavation.\n• The Failure took place on a segment of the Poplar Pipeline between the “North Block\nValve” at milepost (MP) 143.2 on the northwest side of the Yellowstone River and the\n“South Block Valve” at MP 144.4 on the southeast side of the Yellowstone River, near\nGlendive, Montana (Isolated Segment). The pipe segment that failed lay within the\nIsolated Segment and was installed in 1967. Bridger states that this replaced pipe is\nseamless. To confirm this, following the Failure, Bridger excavated a piece of pipe on\nthe bank of the river, and found that it was seamless.\n• The maximum operating pressure (MOP) of the pipeline at the Failure site is 1200 psig,\nas established by hydrostatic test in 1996. At the time of the Failure, the actual operating\npressure of the pipeline was 523 psig.\n• At approximately 12:30pm EST on Saturday, January 17, 2015, the controller in the\nBridger Pipeline control room who was operating the Poplar Pipeline unit observed a\nflow imbalance on his SCADA screen and began to investigate. The abnormal readings\nwere in the segment between the North Block Valve and the South Block Valve on either\nside of the Yellowstone River crossing, approximately 5 miles upstream from Glendive,\nMontana. The two block valves are approximately 6800 feet apart and are motorized\ngates block valves and operated by the company’s control center in Casper, Wyoming.\nShortly thereafter, flow imbalance alarms sounded and the controller began shutting the\npipeline down. The pipeline was shut down at approximately 1:00pm EST and the North\nand South Block Valves were closed. Bridger personnel went out to investigate, but\ncould not ascertain whether there had been a release or not due to considerable ice on the\nriver.\n• Bridger filed a report with NRC at 5:58 pm EST (NRC #1105930), indicating a possible\nrelease into the Yellowstone River. At about 5:00pm EST, Bridger notified local\n\n\n\nCPF No: 5-2015-5003H\nPage 3\nauthorities of a potential release and the Montana Department of Environmental Quality\nnotified municipal water utilities of the potential of crude oil passing by their water\nintakes on the Yellowstone River.\n• At first light on Sunday, January 18, 2015, Bridger discovered an oil sheen in open water\non the Yellowstone River approximately three quarters of a mile downstream from the\npipeline crossing, and also a sheen at approximately 18 miles downstream. No oil sheen\nwas observed at a point approximately 20 miles downstream. Based on this information,\nBridger updated its earlier NRC report to state that there was a release of crude oil into\nthe Yellowstone River. The amended NRC report filed at 10:12am EST on January 18,\n2015, was given a new number (NRC # 1105969).\n• The spill response began at approximately 2:00pm EST on January 18, 2015. Attempts\nto boom the Yellowstone River at Sidney, Montana, approximately 30 miles downstream,\nwere not successful due to river ice.\n• The release amount is not known at this time. A meter-in, meter-out barrel count\nindicates a loss of 300 barrels. The line pack between the two block valves is\napproximately 900 barrels. Therefore it is reasonable to assume 1200 barrels of crude oil\nhas been released, composed primarily of Bakken crude. As of January 23, 2015,\napproximately 274 barrels of crude oil have been recovered.\n• Various state and federal agencies responded to the scene, including the U.S.\nEnvironmental Protection Agency, the U.S. Fish and Wildlife Service, the Montana\nDepartment of Disaster and Emergency Services, the Montana Department of\nEnvironmental Quality, and PHMSA.\n• The cause of the Failure is unknown and the investigation is ongoing. The actual release\nsite has been determined to be in the Yellowstone River near the Southeast bank, but the\nexact location has not been located. The operator has not initiated repairs, as they are still\ntrying to locate the source of the release.\n• The Failure site is upstream from an Ecological Unusually Sensitive Area and Drinking\nWater Unusually Sensitive Area. The Affected Pipeline crosses an additional Ecological\nUnusually Sensitive Area at the Missouri River.\n• The Affected Pipeline is currently partially shut down. The segment from Raymond\nStation to Poplar Station was not operating at the time of the Failure, and is under\nnitrogen blanket. The portion from Poplar Station to the Gas City Creek injection point,\napproximately six miles downstream of the South Block Valve, remains shut down. This\nportion includes the Isolated Segment. The portion of pipeline from the Gas City Creek\ninjection point to Baker Station is currently operating.\n• The accident did not cause any known injuries or evacuations. Low or trace levels of\nhydrocarbons have been detected in the Glendive water system. The water system is\nbeing monitored and Bridger is offering bottled water to Glendive water customers.\n\n\n\nCPF No: 5-2015-5003H\nPage 4\n• Bridger indicates that the Isolated Segment was assessed by hydrostatic test in 1996, in-\nline crack tool in 2010, and in-line MFL tool in 2013. In addition, Bridger conducted a\ndepth of cover survey in 2011 which indicated adequate cover over the pipe.\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility is or would be hazardous, requiring corrective action, is set\nforth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.\nSection 60112 and the regulations promulgated thereunder provide for the issuance of a\nCorrective Action Order, without prior notice and opportunity for hearing, upon a finding that\nfailure to issue the Order expeditiously would result in the likelihood of serious harm to life,\nproperty, or the environment. In such cases, an opportunity for a hearing and expedited review\nwill be provided as soon as practicable after the issuance of the Order.\nAfter evaluating the foregoing preliminary findings of fact, I find that continued operation of the\npipeline without corrective measures is or would be hazardous to life, property, or the\nenvironment. Additionally, having considered the uncertainties as to the cause of the Failure, the\nlocation of the Failure, the material being transported, the proximity of the pipeline to navigable\nwaterways, populated areas, public water intake systems, or other High Consequence Areas, and\nthe inaccessibility of the pipe, I find that a failure to issue this Order expeditiously to require\nimmediate corrective action would result in the likelihood of serious harm to life, property, or the\nenvironment.\nAccordingly, this Corrective Action Order mandating immediate corrective action is issued\nwithout prior notice and opportunity for a hearing. The terms and conditions of this Order are\neffective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may contest its issuance and obtain\nexpedited review either by answering in writing or requesting a hearing under 49 C.F.R.\n§ 190.211, to be held as soon as practicable under the terms of such regulation, by notifying the\nAssociate Administrator for Pipeline Safety in writing, with a copy to the Director, Western\nRegion, OPS (Director). If Respondent requests a hearing, it will be held telephonically or in-\nperson in Denver, Colorado, or Washington, D.C.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. In that event, PHMSA will notify\nRespondent of any additional measures that are required and an amended Order issued, if\nnecessary. To the extent consistent with safety, Respondent will be afforded notice and an\nopportunity for a hearing prior to the imposition of any additional corrective measures.\n\n\n\nCPF No: 5-2015-5003H\nPage 5\nRequired Corrective Actions:\nPursuant to 49 U.S.C. § 60112, I hereby order Bridger to immediately take the following\ncorrective actions to address the January 17, 2015, failure on the Poplar Pipeline:\n1. Shutdown of Affected Pipeline. Bridger must cease operation of the entire Affected\nPipeline, and must not resume operation of the Affected Pipeline until authorized to do so\nby the Director.\n2. Restart Plan. Prior to resuming operation of the Affected Pipeline, Bridger must develop\nand submit a written Restart Plan to the Director for approval.\na. The Director may approve the Restart Plan incrementally without approving the entire\nplan. Segments of the Affected Pipeline may be approved for restart separately, but\ncannot resume operation until all applicable portions of the Restart Plan are approved.\nb. Once approved by the Director, the Restart Plan will be incorporated by reference into\nthis Order.\nc. The Restart Plan must provide for adequate patrolling of the Affected Pipeline during the\nrestart process, to include continuous monitoring at the Glendive and Cabin Creek\nStations, the North Block Valve, the South Block Valve, and the Yellowstone River\nCrossing. The Restart Plan must include incremental pressure increases during start up,\nwith each increment to be held for at least two hours.\nd. The Restart Plan must specify a day-light restart and include advance communications\nwith local emergency response officials.\ne. The Restart Plan must provide for a review of the Affected Pipeline for conditions similar\nto those at the Failure site, including a review of construction, operating and maintenance\n(O&M) and integrity management records such as in-line inspection (ILI) results,\nhydrostatic tests, root cause analysis of prior failures, aerial and ground patrols,\ncorrosion, cathodic protection, excavations and pipe replacements. Operator must\naddress any findings that require remedial measures to be implemented prior to restart.\nf. The Restart Plan must also include documentation of the completion of all mandated\nactions, and a management of change plan to ensure that all procedural modifications are\nincorporated into Bridger’s operations and maintenance procedures manual.\ng. The Restart Plan must provide for hydrostatic pressure testing of the Isolated Segment\nprior to resuming operation. The proposed plan for hydrostatic testing must be at a\npressure sufficient to strength test the pipeline considering the size of any flaws that\nwould survive the pressure test, and conform to the requirements of 49 CFR Part 195,\nSubpart E. The hydrostatic test must also include a 30-minute spike test. Any segments\nof pipe that fail during the testing must be removed and sent to an approved laboratory\nfor metallurgical testing. Respondent must provide continuous patrolling of the Affected\n\n\n\nCPF No: 5-2015-5003H\nPage 6\n3. 4. 5. Pipeline between MP 143.2 and MP 144.4 at the Yellowstone River crossing at all times\nuntil hydrostatic testing is completed.\nOperating Pressure Restriction. After the Director approves the Restart Plan, Bridger\nmay return the pipeline to service but must reduce and maintain a twenty percent (20%)\npressure reduction in the actual operating pressure along the entire length of the pipeline\nsuch that the operating pressure along the pipeline will not exceed eighty percent (80%)\nof the actual operating pressure in effect immediately prior to the failure on January 17,\n2015.\na. This pressure restriction is to remain in effect until written approval to increase the\npressure or return the pipeline to its pre-failure operating pressure is obtained from the\nDirector.\nb. Prior to resuming operation, Bridger must provide the Director the actual operating\npressures of each metering station and each main line pressure regulating station on the\npipeline at the time of Failure and the reduced pressure restriction set-points at these\nsame locations.\nc. This pressure restriction requires any relevant remote or local alarm limits, software\nprogramming set-points or control points, and mechanical over-pressure devices to be\nadjusted accordingly.\nd. When determining the pressure restriction set-points, Bridger must take into account any\nILI features or anomalies present in the pipeline to provide for continued safe operation\nwhile further corrective actions are completed.\ne. Bridger must review the pressure restriction monthly by analyzing the operating pressure\ndata. The company must take into account any ILI features or anomalies present in the\nAffected Pipeline and immediately reduce the operating pressure to maintain the safe\noperations of the Affected Pipeline, if warranted by the monthly review. Bridger must\nsubmit the results of the monthly review to the Director within one week of completion.\nThe results must include, at a minimum, the current discharge set-points (including any\nadditional pressure reductions), and any pressure exceedance at discharge set-points.\nRemoval of Pressure Restriction. The Director may allow the removal or modification\nof the pressure restriction upon a written request from Bridger demonstrating that\nrestoring the pipeline to its pre-failure operating pressure is justified based on a reliable\nengineering analysis showing that the pressure increase is safe considering all known\ndefects, anomalies, and operating parameters of the pipeline.\nRecords Verification. As recommended in PHMSA Advisory Bulletin 2012-06, Bridger\nmust verify the records for the Affected Pipeline to confirm the MOP. Bridger must\nsubmit documentation of this record verification for the Isolated Segment to the Director\nwithin 30 days of receipt of this Order, and within 90 days for the remaining portion of\nthe Affected Pipeline, and must make the supporting records available upon request for\nreview.\n\n\n\nCPF No: 5-2015-5003H\nPage 7\n6. 7. 8. 9. Review of Prior ILI Results. Within 30 days of receipt of this Order, Bridger must\nconduct a review of any previous inline ILI results of the Affected Pipeline and re-\nevaluate all ILI results from the past 10 calendar years, including a review of the ILI\nvendors' raw data and analysis. Bridger must determine whether any features were\npresent in the failed pipe and/or any other pipe removed and determine whether any pipe\nor components with similar characteristics are present elsewhere on the Affected\nPipeline. Bridger must submit documentation of this ILI review to the Director within 45\ndays of receipt of this Order. Additionally, Bridger must make all ILI records and results\navailable to PHMSA’s experts for independent review.\nInline Inspection (ILI). Within 6 months of resuming operation of each segment of the\nAffected Pipeline, Bridger must perform an ILI of the Affected Pipeline. The type of\ntool(s) must be able to detect anomalies of any identified threats, such as seam anomalies,\nmetal loss, or corrosion defects. The Director must provide prior approval of the final\ncriteria and technology considerations taken into account in selecting the specific\ninspection tools. Technology considerations and final criteria should account for the size\n(length and depth) of any possible seam anomalies and the possibility of selective seam\ncorrosion in the Affected Pipeline. The ILI tool must also include consideration of best\navailable technology to reliably detect and size seam anomalies in casings. The data\nanalysis must be completed within 30 days of successful completion of the ILI. The ILI\nvendor must evaluate the results per a performance specification chosen by the operator\nand approved by the Director. The ILI vendor must distribute all reports in their entirety\n(including all media), whether preliminary or final, to the Director and the Respondent at\nthe same time. Within 90 days after performing the ILI, Respondent must submit a final\nreport to the Director with a comparison of the results of this ILI with the results of\nprevious ILIs and criteria and a plan for remediation of anomalies.\nMechanical and Metallurgical Testing. Within 45 days of receipt of this Order,\nBridger must complete independent mechanical and metallurgical testing and failure\nanalysis of the failed pipe, including an analysis of soil samples and any foreign\nmaterials. Complete the testing and analysis as follows:\na. Document the chain-of-custody when handling and transporting the failed\npipeline and other evidence from the failure site.\nb. Within 10 days of receipt of this Order, develop and submit the testing protocol\nand the proposed testing laboratory to the Director for prior approval.\nc. At least seven days prior to beginning the mechanical and metallurgical testing,\nprovide the Director with the scheduled date, time, and location of the testing to\nallow for an OPS representative to witness the testing.\nd. Ensure the testing laboratory distributes all reports whether draft or final in their\nentirety to the Director at the same time they are made available to Bridger.\nRoot Cause Failure Analysis. Within 60 days following receipt of this Order, Bridger\nmust complete a root cause failure analysis (RCFA) and submit a final report of this\n\n\n\n10. 11. CPF No: 5-2015-5003H\nPage 8\nRCFA to the Director. The RCFA must be facilitated by an independent third-party\nacceptable to the Director and must document the decision-making process and all factors\ncontributing to the failure. The final report must include findings and any lessons learned\nand whether the findings and any lessons learned are applicable to other locations within\nBridger’s pipeline system.\nEmergency Response Plan and Training Review. Bridger must review and assess the\neffectiveness of its emergency response plan and oil spill response plan with regards to\nthe Failure. Include in the review and assessment the on-scene response and support,\ncoordination, and communication with emergency responders and public officials. As\npart of this review, Bridger should seek input from Federal, State, and Local officials and\nagencies who participated in the actual response. Also, include a review and assessment\nof the effectiveness of its emergency training program. Bridger must amend its\nemergency response plan and emergency training, if necessary, to reflect the results of\nthis review. The documentation of this Emergency Response Plan and Training Review\nmust be available for inspection by OPS or provided to the Director, if requested.\nRevisions to the Oil Spill Response Plan must be submitted to the Director, Emergency\nSupport, and Security Division for review and approval in accordance with 49 C.F.R.\nPart 194.\nOperational Integrity and Remediation Plan (OIRP).\na. Within 90 days following receipt of this Order, Bridger must submit an\nOperational Integrity and Remediation Plan (OIRP) to the Director for approval.\nb. The Director may approve the OIRP incrementally without approving the entire\nOIRP.\nc. Once approved by the Director, the OIRP will be incorporated by reference into\nthis Order.\nd. The OIRP must specify the tests, inspections, assessments, evaluations, and\nremedial measures Bridger will use to verify the integrity of the pipeline. It must\naddress all known or suspected factors and causes of the January 17, 2015, failure.\nBridger should consider both the risk of another failure and the consequence of\nanother failure to develop a prioritized schedule for OIRP related work along the\nAffected Segment.\ne. The OIRP must include a procedure or process to:\ni. Identify pipe along the pipeline with characteristics similar to the\ncontributing factors identified for the January 17, 2015, failure.\nii. Gather all data necessary to review the failure history (in service and\npressure test failures) of the Affected Pipeline and to prepare a written\nreport containing all the available information such as the locations, dates,\nand causes of leaks and failures.\n\n\n\nCPF No: 5-2015-5003H\nPage 9\niii. Integrate the results of the metallurgical testing, root cause failure\nanalysis, and other corrective actions required by this Order with all\nrelevant pre-existing operational and assessment data for the pipeline.\nPre-existing operational data includes, but is not limited to, construction,\noperations, maintenance, testing, repairs, prior metallurgical analyses, and\nany third party consultation information. Pre-existing assessment data\nincludes, but is not limited to, ILI tool runs, hydrostatic pressure testing,\ndirect assessments, close interval surveys, and DCVG/ACVG surveys.\niv. Determine whether conditions similar to those contributing to the failure\non January 17, 2015, are likely to exist elsewhere on the pipeline.\nv. Conduct additional field tests, inspections, assessments, and/or evaluations\nto determine whether, and to what extent, the conditions associated with\nthe failure on January 17, 2015, and other failures from the failure history\nor any other integrity threats are present elsewhere on the Affected\nPipeline. This process must include a risk assessment of all water\ncrossings greater than 100 feet and an analysis of whether Horizontal\nDirectionally Drilled (HDD) crossings should be installed at these\nlocations. This process must consider all failure causes and specify the\nuse of one or more of the following:\n1) Inline inspection (ILI) tools that are technically appropriate for\nassessing the pipeline system based on the cause of failure on\nJanuary 17, 2015, and that can reliably detect and identify\nanomalies,\n2) Hydrostatic pressure testing,\n3) Close-interval surveys,\n4) Cathodic protection surveys, to include interference surveys in\ncoordination with other utilities (e.g. underground utilities,\noverhead power lines, etc.) in the area,\n5) Coating surveys,\n6) Stress corrosion cracking surveys,\n7) Selective seam corrosion surveys; and,\n8) Other tests, inspections, assessments, and evaluations appropriate\nfor the failure causes.\nvi. Describe the inspection and repair criteria Bridger will use to prioritize,\nexcavate, evaluate, and repair anomalies, imperfections, and other\nidentified integrity threats. Include a description of how any defects will\nbe graded and a schedule for repairs or replacement.\nvii. Based on the known history and condition of the pipeline, describe the\nmethods Bridger will use to repair, replace, or take other corrective\nmeasures to remediate the conditions associated with the pipeline failure\non January 17, 2015, and to address other known integrity threats along\nthe Affected Pipeline. The repair, replacement, or other corrective\nmeasures must meet the criteria specified in the paragraph (vi) above. At\na minimum, HDD pipeline crossings must be installed at the Yellowstone\nRiver and Poplar River crossings within 90 days after resuming operation\nat the respective pipeline crossing.\n\n\n\n12. CPF No: 5-2015-5003H\nPage 10\nviii. Provide the Director with the scheduled date, time, and location of any\npipe removal or installation to allow for a PHMSA representative to\nwitness the work.\nix. Implement continuing long-term periodic testing and integrity verification\nmeasures to ensure the ongoing safe operation of the Affected Pipeline\nconsidering the results of the analyses, inspections, evaluations, and\ncorrective measures undertaken pursuant to the Order.\nf. Include a proposed schedule for completion of the OIRP.\ng. Bridger must revise the OIRP as necessary to incorporate new information\nobtained during the failure investigation and remedial activities, to incorporate the\nresults of actions undertaken pursuant to this Order, and/or to incorporate\nmodifications required by the Director.\ni. Submit any plan revisions to the Director for prior approval.\nii. The Director may approve plan revisions incrementally.\niii. Any and all revisions to the OIRP after it has been approved and\nincorporated by reference into this Order will be fully described and\ndocumented in the CAO Documentation Report (CDR).\nh. Implement the OIRP as it is approved by the Director, including any revisions to\nthe plan.\nCAO Documentation Report (CDR). Bridger must create and revise, as necessary, a\nCAO Documentation Report (CDR). When Bridger has concluded all the items in this\nOrder it will submit the final CDR in its entirety to the Director. This will allow the\nDirector to complete a thorough review of all actions taken by Bridger with regards to\nthis Order prior to approving the closure of this Order. The intent is for the CDR to\nsummarize all activities and documentation associated with this Order in one document.\na. The Director may approve the CDR incrementally without approving the entire\nCDR.\nb. Once approved by the Director, the CDR will be incorporated by reference into\nthis Order.\nc. The CDR must include but not be limited to:\ni. Table of Contents;\nii. Summary of the pipeline failure of January 17, 2015, and the response\nactivities;\niii. Summary of pipe data/properties and all prior assessments of the Affected\nSegment;\niv. Summary of all tests, inspections, assessments, evaluations, and analysis\nrequired by the Order;\nv. Summary of the Mechanical and Metallurgical Testing as required by the\nOrder;\n\n\n\nCPF No: 5-2015-5003H\nPage 11\nvi. vii. Summary of the RCFA with all root causes as required by the Order;\nDocumentation of all actions taken by Bridger to implement the OIRP, the\nresults of those actions, and the inspection and repair criteria used;\nviii. Documentation of any revisions to the OIRP including those necessary to\nincorporate the results of actions undertaken pursuant to this Order and\nwhenever necessary to incorporate new information obtained during the\nfailure investigation and remedial activities;\nix. x. Lessons learned while completing this Order;\nA path forward describing specific actions Bridger will take on its entire\npipeline system as a result of the lessons learned from work on this Order;\nand\nxi. Appendices (if required).\nOther Requirements:\n1. Reporting. Bridger must submit quarterly reports to the Director that: (1) include all\navailable data and results of the testing and evaluations required by this Order; and (2)\ndescribe the progress of the repairs or other remedial actions being undertaken. The first\nquarterly report is due on March 31, 2015. The Director may change the interval for the\nsubmission of these reports.\n2. Approvals. With respect to each submission requiring the approval of the Director, the\nDirector may: (a) approve the submission in whole or in part; (b) approve the submission\non specified conditions; (c) modify the submission to cure any deficiencies; (d)\ndisapprove the submission in whole or in part and direct Respondent to modify the\nsubmission; or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, Respondent shall proceed to take all action\nrequired by the submission, as approved or modified by the Director. If the Director\ndisapproves all or any portion of a submission, Respondent must correct all deficiencies\nwithin the time specified by the Director and resubmit it for approval.\n3. Extensions of Time. The Director may grant an extension of time for compliance with\nany of the terms of this Order upon a written request timely submitted and demonstrating\ngood cause for an extension.\n4. Documentation of Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Order. Include in each\nquarterly report the to-date total costs associated with: (1) preparation and revision of\nprocedures, studies and analyses; (2) physical changes to pipeline infrastructure,\nincluding repairs, replacements and other modifications; and (3) environmental\nremediation, if applicable.\nThe actions required by this Corrective Action Order are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under 49 C.F.R. Part 195, under any\n\n\n\nCPF No: 5-2015-5003H\nPage 12\nother order issued to Respondent under authority of 49 U.S.C. § 60101, et seq., or under any\nother provision of Federal or State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.\n§ 60120.\nIn your correspondence on this matter, please refer to CPF No. 5-2015-5003H and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nThe terms and conditions of this Corrective Action Order are effective upon receipt.\n__________________________________ ____January 23, 2015______________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":35709}