{"operation":"document","citation":"CPF 52023015WL","title":"BRIDGER PIPELINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-03-01","effective_on":null,"summary":"CLOSED warning letter citing 195.428(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023015wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023015wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52023015wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52023015WL","body":"Warning Letter involving BRIDGER PIPELINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.428(a). The case was opened on 2023-03-01 and is reported as closed as of 2023-03-01. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52023015WL_Warning Letter_03012023_(22-236100).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023015WL/52023015WL_Warning%20Letter_03012023_(22-236100).pdf\n\n52023015WL_Warning Letter_03012023_(22-236100)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52023015WL/52023015WL_Warning%20Letter_03012023_(22-236100)_text.pdf\n\n52023015WL_Warning Letter_03012023_(22-236100)_text.pdf\n\nWARNING LETTER\nVIA E-MAIL TO MR. TAD TRUE\nMarch 1, 2023\nMr. Tad True\nVice President\nBridger Pipeline LLC\nPO Box 2360\nCasper, WY 82602-2360\nCPF 5-2023-015-WL\nDear Mr. True:\nFrom July 19, 2022, to September 16, 2022, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), inspected\nthe Butte pipeline system from Baker, Montana to Guernsey, Wyoming.\nAs a result of the inspection, it is alleged that you have committed a probable violation of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable\nviolation is:\n1. § 195.428 Overpressure safety devices and overfill protection systems.\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the case of\npipelines used to carry highly volatile liquids, at intervals not to exceed 7 ½ months, but at\nleast twice each calendar year, inspect and test each pressure limiting device, relief valve,\npressure regulator, or other item of pressure control equipment to determine that it is\nfunctioning properly, is in good mechanical condition, and is adequate from the standpoint\nof capacity and reliability of operation for the service in which it is used.\nBridger Pipeline failed to inspect and test overpressure safety devices at intervals not exceeding 15\nmonths, but at least once each calendar year. Specifically, while overpressure safety devices were\ninspected and tested at intervals not exceeding 15 months, they were not tested at least once each calendar\n\n\n\nyear. Bridger Pipeline did not inspect and test overpressure safety devices at Alzada, Cheyenne, Hulett,\nand Osage pump station for the calendar year 2021.1\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related series\nof violations. For violation occurring on or after March 21, 2022 and before January 6, 2023, the\nmaximum penalty may not exceed $239,142 per violation per day the violation persists, up to a maximum\nof $2,391,142 for a related series of violations. For violation occurring on or after May 3, 2021 and before\nMarch 21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation\npersists, up to a maximum of $2,251,334 for a related series of violations. For violation occurring on or\nafter January 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per\nviolation per day the violation persists, up to a maximum of $2,225,034 for a related series of violations.\nFor violation occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may\nnot exceed $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 July 31,\n2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not\nto exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November 27,\n2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not\nto exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case and have decided\nnot to conduct additional enforcement action or penalty assessment proceedings at this time. We advise\nyou to correct the item identified in this letter. Failure to do so will result in Bridger Pipeline being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply in your correspondence, please refer to CPF 5-\n2023-015-WL. Be advised that all material you submit in response to this enforcement action is subject\nto being made 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 must\nprovide a second copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nSincerely,\nDustin Hubbard\nDirector, Western Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Williams, J. Luo (#22-236100)\nDoug Thacker – DOT Primary Compliance (doug.thacker@truecos.com)\n1 See Exhibit A-1 (attached and on file with PHMSA) (depicting Bridger’s PL-504 form that denote inspections\nwere performed in 2020 and 2022 but not in 2021).","truncated":false,"body_characters":5507}