BRIDGER PIPELINE LLC — Warning Letter

52023015WL_Warning Letter_03012023_(22-236100)_text.pdf, page 1Official PDFWARNING LETTER VIA E-MAIL TO MR. TAD TRUE March 1, 2023 Mr. Tad True Vice President Bridger Pipeline LLC PO Box 2360 Casper, WY 82602-2360 CPF 5-2023-015-WL Dear Mr. True: From July 19, 2022, to September 16, 2022, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected the Butte pipeline system from Baker, Montana to Guernsey, Wyoming. As a result of the inspection, it is alleged that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable violation is: 1. § 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 7 ½ 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 Pipeline failed to inspect and test overpressure safety devices at intervals not exceeding 15 months, but at least once each calendar year. Specifically, while overpressure safety devices were inspected and tested at intervals not exceeding 15 months, they were not tested at least once each calendar#

52023015WL_Warning Letter_03012023_(22-236100)_text.pdf, page 2year. Bridger Pipeline did not inspect and test overpressure safety devices at Alzada, Cheyenne, Hulett, and Osage pump station for the calendar year 2021.1 Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related series of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,142 for a related series of violations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. We have reviewed the circumstances and supporting documents involved in this case and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct the item identified in this letter. Failure to do so will result in Bridger Pipeline being subject to additional enforcement action. No reply to this letter is required. If you choose to reply in your correspondence, please refer to CPF 5- 2023-015-WL. 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). Sincerely, Dustin Hubbard Director, Western Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: PHP-60 Compliance Registry PHP-500 J. Williams, J. Luo (#22-236100) Doug Thacker – DOT Primary Compliance (doug.thacker@truecos.com) 1 See Exhibit A-1 (attached and on file with PHMSA) (depicting Bridger’s PL-504 form that denote inspections were performed in 2020 and 2022 but not in 2021).#