BRIDGER SWAN RANCH, LLC — Notice of Amendment

party submissionOfficial PDF520176005M_Operator Response To Notice_03102017.pdf#

520176005M_Closure Letter_05102017_text.pdf, page 1Official PDFVIA FED EX – TRACKING NO. 7791 0734 0653 May 10, 2017 Mr. Julio E. Rios II President and Chief Executive Officer Bridger Logistics LLC 2009 Chenault Drive #100 Carrolton, Texas 75006 CPF 5-2017-6005M Closure Letter Dear Mr. Rios: On August 29 through September 2, 2016, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code, conducted an on-site pipeline safety inspection of Bridger Logistics LLC’s Swan Ranch procedures in Cheyenne, Wyoming. As a result of the inspection, Bridger Logistics LLC was issued a Notice of Amendment (NOA) on February 16, 2017, which proposed amendment of your procedures. Bridger Logistics submitted its second amended procedures on March 31, 2017 in response to a clarification request. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Chris Hoidal Director, Western Region Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 G. Ogirima#

520176005M_Notice of Amendment_02162017_text.pdf, page 1Official PDFNOTICE OF AMENDMENT VIA FEDEX – TRACKING NO. 7784 4394 1303 February 16, 2017 Mr. Julio E. Rios II President and Chief Executive Officer Bridger Logistics LLC 2009 Chenault Drive #100 Carrollton, Texas 75006 CPF 5-2017-6005M Dear Mr. Rios: On August 29 through September 2, 2016, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Bridger Logistics LLC’s procedures for your Swan Ranch (Swan Ranch) facilities in Cheyenne, Wyoming. On the basis of the inspection, PHMSA has identified these apparent inadequacies within the Bridger Logistics Swan Ranch plans or procedures, as described below:#

520176005M_Notice of Amendment_02162017_text.pdf, page 21. §195.402 Procedural manual for operations, maintenance, and emergencies. (e) Emergencies. The manual required by paragraph (a) of this section must include procedures for the following to provide safety when an emergency condition occurs; (9) Providing for a post-accident review of employee activities to determine whether the procedures were effective in each emergency and taking corrective action where deficiencies are found. Bridger Logistics LLC’s Operations and Maintenance Manual did not contain adequate procedures for conducting a post-accident review. Should an accident occur at Swan Ranch, the manual must ensure there are adequate procedures to define who conducts the review, conduct of the review, and how identified deficiencies are corrected. 2. §195.428 Overpressure safety devices and overfill protection systems (a) Except as provided in paragraph (b) of this section, each operator shall, at intervals not exceeding 15 months, but at least once each calendar year, or in the case of pipelines used to carry highly volatile liquids, at intervals not to exceed 7½ months, but at least twice each calendar year, inspect and test each pressure limiting device, relief valve, pressure regulator, or other item of pressure control equipment to determine that it is functioning properly, is in good mechanical condition, and is adequate from the standpoint of capacity and reliability of operation for the service in which it is used. Bridger Logistics LLC’s Operations and Maintenance Manual did not contain adequate procedures for identifying and inspecting overfill protection devices that protect the Swan Ranch assets. 3. §195.442 Damage Prevention Program (c) The damage prevention program required by paragraph (a) of this section must, at a minimum: (6) Provide as follows for inspection of pipelines that an operator has reason to believe could be damaged by excavation activities: (i) The inspection must be done as frequently as necessary during and after the activities to verify the integrity of the pipeline; and (ii) In the case of blasting, any inspection must include leakage surveys. Bridger Logistics LLC’s Operations and Maintenance Manual, page 69 of 99, states that “Company personnel, upon arrival at the excavation site, shall assess the pipeline right-of- way for encroachment violations in accordance with the procedure entitled “Encroachments” of this manual.” The encroachment section of the Operations and Maintenance Manual, however, was not available at the time of the inspection.#

520176005M_Notice of Amendment_02162017_text.pdf, page 34. §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. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. Bridger Logistics LLC’s Operations and Maintenance Manual did not contain adequate procedures for installing cathodic protection on breakout tanks in accordance with subpart H §195.571. 5. §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. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. Bridger Logistics LLC’s Operations and Maintenance Manual, page 32 of 99, paraphrases 195.403 and does not include facility-specific procedures. Bridger Logistics must establish and conduct a continuing training program to instruct emergency personnel on emergency response as required by 195.403.#

520176005M_Notice of Amendment_02162017_text.pdf, page 46. §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. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. Bridger Logistics LLC’s Operations and Maintenance Manual refers to a pipeline repair section in its Integrity Management Program to comply with the requirement of §195.422 (a). This repair section does not exist in its Integrity Management Program. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance Proceedings. Please refer to this document and note the response options. 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Bridger Logistics LLC maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Chris Hoidal, Director,#

520176005M_Notice of Amendment_02162017_text.pdf, page 5Western, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 5-2017-6005M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Chris Hoidal Director, Western Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings cc: PHP-60 Compliance Registry PHP-500 Ogirima (#154091)#