{"operation":"document","citation":"CPF 520195016W","title":"BRIDGER PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-12-12","effective_on":null,"summary":"CLOSED warning letter citing 195.452(l).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195016w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195016w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520195016w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520195016W","body":"Warning Letter involving BRIDGER PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.452(l). The case was opened on 2019-12-12 and is reported as closed as of 2019-12-12. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520195016W_Warning Letter_12122019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195016W/520195016W_Warning%20Letter_12122019.pdf\n\n520195016W_Warning Letter_12122019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520195016W/520195016W_Warning%20Letter_12122019_text.pdf\n\n520195016W_Warning Letter_12122019_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nDecember 12, 2019\nMr. H. A. True, III\nPresident\nBridger Pipeline LLC\nP.O. Box 2360\nCasper, WY 82602-2360\nCPF 5-2019-5016W\nDear Mr. True:\nOn January 31 through February 1, August 5 through 9, August 12 through 16, and September 9\nthrough 13, a representative of the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected your Bridger\nPipeline LLC’s Poplar Crude System in Casper, Wyoming and in the Glendive, Montana area.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected\nand the probable violations is:\n1. § 195.452 Pipeline integrity management in high consequence areas.\n(a) . . .\n(l) What records must an operator keep to demonstrate compliance? (1) An\noperator must maintain, for the useful life of the pipeline, records that demonstrate\ncompliance with the requirements of this subpart. At a minimum, an operator must\nmaintain the following records for review during an inspection:\n\n\n\n(i) A written integrity management program in accordance with paragraph (b) of\nthis section.\n(ii) Documents to support the decisions and analyses, including any modifications,\njustifications, deviations and determinations made, variances, and actions taken, to\nimplement and evaluate each element of the integrity management program listed in\nparagraph (f) of this section.\nBridger Pipeline lacked documents that supported the decision of which type of In-Line-\nInspection (ILI) tool was selected. The type of ILI assessment tool selected was listed in the ILI\nschedule. The ILI schedule lacked justification as to why the specific ILI tool was selected based\non threats identified for the pipeline.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related\nseries of violations. For violation occurring on or after November 27, 2018 and before July 31,\n2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum\npenalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and\nbefore November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day,\nwith a maximum penalty not to exceed $2,090,022. For violations occurring prior to November 2,\n2015, the maximum penalty may not exceed $200,000 per violation per day, with a maximum\npenalty not to exceed $2,000,000 for a related series of violations. We have reviewed the\ncircumstances and supporting documents involved in this case, and have decided not to conduct\nadditional enforcement action or penalty assessment proceedings at this time. We advise you to\ncorrect the item 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 to\nCPF 5-2019-5016W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 Jeff Gilliam (#162663)\nJared Radosevich, Pipeline Compliance Coordinator (via email)\n2","truncated":false,"body_characters":4566}