{"operation":"document","citation":"CPF 520205004W","title":"FRONT RANGE PIPELINE, LLC. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2020-04-15","effective_on":null,"summary":"CLOSED warning letter citing 195.402(c)(3), 195.420(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520205004w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520205004w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520205004w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520205004W","body":"Warning Letter involving FRONT RANGE PIPELINE, LLC.. PHMSA's enforcement data identifies the cited regulations as 195.402(c)(3),  195.420(a). The case was opened on 2020-04-15 and is reported as closed as of 2020-04-15. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520205004W_Operator Response To Notice_07162020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520205004W/520205004W_Operator%20Response%20To%20Notice_07162020.pdf\n\n520205004W_Warning Letter_04152020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520205004W/520205004W_Warning%20Letter_04152020.pdf\n\n520205004W_Warning Letter_04152020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520205004W/520205004W_Warning%20Letter_04152020_text.pdf\n\n520205004W_Warning Letter_04152020_text.pdf\n\nWARNING LETTER\nVIA E-MAIL TO MR. RICHARD PETERSEN\nApril 15, 2020\nMr. Richard Petersen\nPresident\nFront Range Pipeline, LLC\n803 Highway 212 South\nLaurel, MT 59044\nCPF 5-2020-5004W\nDear Mr. Petersen:\nOn March 5, 2019, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.),\ninvestigated the accident that occurred on March 4, 2019 at Judith Gap Pump Station, MP 218\nnear Judith Gap, Montana.\nAs a result of the inspection, it is alleged that you have committed Probable Violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n\n\n\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) . . .\n(3) Operating, maintaining, and repairing the pipeline system in accordance with\neach of the requirements of this subpart and subpart H of this part.\nThere appears to be a lack of guidance for the inspection of Flange Bolt Torque requirements on\nmainline flanges of appurtenances. It is recommended that a written procedure for Flange Bolt\nTorque Inspections be added to the company’s O&M Manual that includes at a minimum,\nidentification of all flanges to be inspected, locations of each flange, manufacturer specifications\nto be followed during the inspection, and at what frequency inspections will occur.\n2. §195.420 Valve Maintenance\n(a) Each operator shall maintain each valve that is necessary for the safe\noperation of its pipeline systems in good working order at all times.\nFront Range Pipeline (FRP) does not consider its check valves on the mainline to be “necessary\nfor the safe operation of the pipeline” and therefore does not inspect them pursuant to 49 C.F.R.\n§ 195.420. However, there is a mainline check valve at each pump station on the CHS Front\nRange Pipeline system. While FRP may not currently consider all of these valves to be\n“necessary” to operate its pipeline, the fact remains that the design and construction of the\npipeline included these valves and FRP has elected not to remove them. These valves are\nstrategically placed to insure the proper flow direction of fluid in the mainline when the pump\nstation is operating. Therefore, it is PHMSA’s opinion that these check valves are necessary for\nthe safe operation of the pipeline. We recommend that, to the maximum extent practicable,\nmainline check valves be inspected and tested at the same frequency as the mainline gate valves.\nWhere possible, we recommend that this be done during scheduled system shutdowns so Front\nRange Pipeline personnel can monitor pipeline pressure on the upstream and downstream sides\nof each check valve using the valve bypass piping. The results of this pressure monitoring will\nallow Front Range Pipeline to qualitatively assess the condition of their check valves, and\ndetermine the need for additional valve maintenance.\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\nrelated series of violations. For violation occurring on or after November 27, 2018 and before\nJuly 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a\nmaximum penalty not to exceed $2,132,679. For violation occurring on or after November 2,\n2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per\nviolation per day, with a maximum penalty not to exceed $2,090,022. For violations occurring\nprior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per\n2\n\n\n\nday, with a maximum penalty not to exceed $2,000,000 for a related series of violations. We\nhave reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in\nFront Range Pipeline, LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-2020-5004W. 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\nthe redacted 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 A. Ceartin (#164709)\nMichelle Slyder, Manager DOT Compliance CHS\n3","truncated":false,"body_characters":6022}