U.S. Department 
of Transportation 
400 Seventh Street, S.W. 
Washington, D.C. 20590 
Pipeline and 
Hazardous Materidls Safety 
Administration 
JUL 1 0 : ' b w , i 
Mr. Hank A. True I11 
President 
Belle Fourche Pipeline Company 
895 W. River Cross Road 
Casper, WY 82602 
Re: CPF No. 5-2004-5030 
Dear Mr. True: 
Enclosed is the Final Order issued by the Associate Administrator for Pipeline Safety in 
the above-referenced case. It makes findings of violation and assesses a civil penalty of 
$50,000. The Final Order also specifies actions to be taken to comply with the pipeline safety 
regulations and requires the revision of certain of your operating and maintenance procedures. 
The penalty payment terms are set forth in the Final Order. When the pivil penalty is paid and 
the terms of the Compliance Order and Amendment of Procedures are completed, as 
determined by the Director, Western Region, this enforcement action *ill be closed. Your 
receipt of the Final Order constitutes service under 49 C.F.R. Ħħ 190.5. 
Sincerely, 
'U 
James Reynolds 
Pipeline Compliance Registry 
Office of Pipeline Safety 
Enclosure 
CERTIFIED MAIL -RETURN RECEIPT REQUESTED 

DEPARTMENT OF TRANSPORTATION ~ 
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 
OFFICE OF PIPELINE SAFETY 
WASHINGTON, DC 20590 
) 
In the Matter of 1 
Belle Fourche Pipeline Company, 
)
1 CPF NO. 4-2004-5030 
Respondent 
)
1 
FINAL ORDER 
Between May 17 and 19,2004, pursuant to 49 U.S.C. Ħħ 601 17, representatives of the Pipeline 
and Hazardous Materials Safety Administration's (PHMSA's) Office of Pipeline Safety 
conducted an on-site pipeline safety inspection of Respondent's integrity management program 
(IMP) in Casper, Wyoming. As a result of the inspection, the Director, Western Region, 
PHMSA issued to Respondent, by letter dated September 30,2004, a Notice of Probable 
Violation, Proposed Civil Penalty, Proposed Compliance Order, and Notice of Amendment 
(Notice).' In accordance with 49 C.F.R. 190.207, the Notice proposed finding that Respondent 
committed violations of 49 C.F.R. Part 195, proposed assessing a civil penalty of $50,000 for 
one of the alleged violations, and proposed that Respondent take certain measures to correct 
another of the alleged violations. The Notice also alleged inadequacies ip Respondent's IMP and 
proposed to require amendment of Respondent's procedures to comply with the requirements of 
49 C.F.R. 195.452. 
Respondent failed to respond within 30 days after it had received the Notice. Under 
49 C.F.R. tj 190.209(c), Respondent's failure to respond constitutes a waiver of Respondent's 
right to contest the allegations in the Notice and authorizes the entry of this Final Order. 
FINDINGS OF VIOLATION 
Respondent did not contest the alleged violations in the Notice. Accordingly, I find that 
Respondent violated the following sections of 49 C.F.R. Part 195 as more fully described in the 
Notice: 
' Effective February 20,2005, the Pipeline and Hazardous Materials Safety Administration (PHMSA) succeeded 
Research and Special Programs Administration as the agency responsible for regulating safety in pipeline 
transportation and hazardous materials transportation. See, section 108 of the Norman Y. Mineta Research and 
Special Programs Improvement Act (Public Law 108-426, 118 Stat. 2423-2429 (November 30,2004)). See also, 70 
Fed. Reg. 8299 (February 18, 2005) redelegating the pipeline safety authorities and functions to the PHMSA 
Administrator. 

Item 2(a)-49 C.F.R. 9 195.452(c)-failing to establish a baseline integrity assessment 
schedule prioritizing its pipeline segments based on all risk factors that reflect the risk 
conditions on each segment; and 
Item 2(b)-49 C.F.R. Ħħ 195.452(c)-failing to include a seam failure susceptibility 
analysis on all pipeline segments containing low frequency electric resistance welded 
pipe (ERW) and lap welded pipe to determine which segments are susceptible to seam 
failure prior to selecting baseline integrity assessment methods for applicable segments. 
These findings of violation will be considered prior offenses in any subsequent enforcement 
action taken against Respondent. 
ASSESSMENT OF PENALTY 
Under 49 U.S.C. Ħħ 60 122, Respondent is subject to a civil penalty not to exceed $100,000 per 
violation for each day of the violation up to a maximum of $1,000,000 for any related series of 
violations. 
49 U.S.C. 5 60122 and 49 C.F.R. 9 190.225 require that, in determining the amount of the civil 
penalty, I consider the following criteria: nature, circumstances, and gravity of the violation, 
degree of Respondent's culpability, history of Respondent's prior offenses, Respondent's ability 
to pay the penalty, good faith by Respondent in attempting to achieve compliance, the effect on 
Respondent's ability to continue in business, and such other matters as justice may require. 
Item 2(a) of the Notice proposed a civil penalty of $50,000.00 for violation of 
49 C.F.R. $ 195.452(c). Respondent violated 49 C.F.R. Ħħ 195.452(c) in that it did not develop a 
BAP that uses risk factors in establishing the base line assessment methads and schedule. 
Prioritizing pipeline segments for integrity assessments by risk is a key step in managing pipeline 
integrity. Respondent did not provide information that would warrant a reduction in the civil 
penalty amount proposed in the Notice. 
Accordingly, having reviewed the record and considered the assessment criteria, I assess 
Respondent a total civil penalty of $50,000 for violation of 49 C.F.R. $ 195.452(c). Respondent 
has the ability to pay this penalty without adversely affecting its ability tio continue in business. 
Payment of the civil penalty must be made within 20 days of service. Federal regulations 
(49 C.F.R. 8 89.21(b)(3)) require this payment be made by wire transfer, through the Federal 
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed 
instructions are contained in the enclosure. Questions concerning wire transfers should be 
directed to: Financial Operations Division (AMZ-300), Federal Aviation Administration, Mike 
Monroney Aeronautical Center, P.O. Box 25082, Oklahoma City, OK 73 125; (405) 954-8893. 
Failure to pay the $50,000 civil penalty will result in accrual of interest at the current annual rate 
in accordance with 31 U.S.C. Ħħ 3717,31 C.F.R. 9 901.9 and 49 C.F.R. 8 89.23. Pursuant to 
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if 

payment is not made within 1 10 days of service. Furthermore, failure to pay the civil penalty 
may result in referral of the matter to the Attorney General for appropriatq action in a United 
States District Court. 
COMPLIANCE ORDER 
The Notice proposed a compliance order with respect to Item 2(b) in the Notice. Under 49 
U.S.C. 
5 601 18(a), each person who engages in the transportation of hazardous liquids or who 
owns or operates a pipeline facility is required to comply with the applicable safety standards 
established under Chapter 601. Pursuant to the authority of 49 U.S.C. $601 18(b) and 49 C.F.R. 
8 190.21 7, Respondent is ordered to take the following actions to ensure compliance with the 
pipeline safety regulations applicable to its operations: 
1. 
With respect to Item 2(b) of the Notice, perform a seam failure susceptibility analysis 
on all pipeline segments containing low-frequency (ERW) and lap welded pipe to 
determine which segments are susceptible to seam failure. This analysis must 
conclude which assessment methods are capable of addressing their specific seam 
issues; 
2. 
Document the costs associated with fblfilling this Compliance Order and submit the 
documentation to the Director, Western Region, Office of Pipeline Safety, Pipeline 
and Hazardous Materials Safety Administration, 12300 West Dakota Ave, #110, 
Lakewood, Colorado 80228. Please refer to CPF No. 5-2004-5030 on all 
correspondence; and 
3. 
Complete the above items within 60 days of receipt of this Final Order and submit the 
required documentation and procedures to the Director, Western Region, Office of 
Pipeline Safety. 
The Director, Western Region, may grant an extension of time to comply with any of the 
required items upon a written request timely submitted by Respondent demonstrating good cause 
for an extension. 
Failure to comply with this Order may result in the assessment of civil penalties of not more than 
$100,000 per day and in referral to the Attorney General for appropriate relief in a United States 
District Court. 
AMENDMENT OF PROCEDURES 
Items l(a-d), 2(c-d), 3(b), 4,5(a-b), 6,7(a-d), 8(a-f), 9(a-d), lO(a-b), and 1 1 of the Notice alleged 
inadequacies in Respondent's IMP and proposed to require amendment of Respondent's 
procedures to comply with the requirements of 49 C.F.R. 195.452. 
Respondent did not contest the Notice of Amendment. Accordingly, I find that Respondent's 
procedures as described in the Notice are inadequate to ensure safe operation of its pipeline 

system. Pursuant to 49 U.S.C. 5 60 108(a) and 49 C.F.R. 5 1 90.237, Resp~ndent is ordered to 
make the following revisions to its procedures: 
1. 
Amend its IMP to include an evaluation of each individual pipeline facility to 
determine whether a release incident could affect a High Consequence Area (HCA). 
This analysis must include potential facility release volumes; 
2. 
Amend its IMP to properly define the boundaries of those segments that could affect 
a HCA. A properly defined pipeline segment could affect a EICA at any location 
between its end points; 
3. 
Amend its IMP to include technical justification showing that their use of the one 
mile area of impact for on-land spills is conservative; 
4. 
Amend their IMP to include technical justification for the assumption that any 
segment of pipeline that crosses a stream with a HCA is considered to affect that 
HCA; 
5 . 
Amend its IMP BAP so that it consolidates all portions of Respondent's system and 
includes: 1) the required assessment schedule; 2) an explanatlion of assessment 
methods selected and; 3) the risk analysis results used to establish the schedule; 
6. 
Amend its IMP BAP to include a process for revising the BAP and appropriately 
documenting those revisions; 
7. 
Amend its IMP baseline assessment schedule to ensure that 50% of Category 2 pipe 
are assessed by the applicable regulatory deadline; 
8. 
Amend its IMP to include a process for the incorporation of changes that may cause 
new segments of its pipeline to affect a HCA; 
9. 
Amend its IMP to include training and qualification requirements for personnel 
performing key integrity management functions (e.g., review of assessment results, 
risk analysis); 
10. 
Amend its IMP to include criteria for: 1) vendor in-line-inspection (ILI) tool 
tolerances; 2) vendor reporting requirements; 3) operatorlvendor process for 
resolution of variances and problems; 4) vendor ILI assessment personnel 
qualifications. One possible solution is to develop vendor specifications; 
1 1. Amend its IMP to include a process to correlate ILI indications with other data such 
as cathodic protection (CP) monitoring, one-call records, etc; 
12. 
Amend its IMP to include processes for validating assessment results and for making 
tool tolerance adjustments resulting from validation activities; 

Amend its IMP to include a method for determining the amount of immediate repair 
pressure reduction, or provide guidance to use an alternate 20% pressure reduction, 
when ASMEJANSI B3 1.4 45 1.7 does not apply; 
Amend its IMP to include a process for the prioritization and scheduling of 
remediation activities resulting from assessment activities [Ref. 5192.452(h)(3)]; 
Amend its IMP to include procedures to notify PHMSA if the remediation schedule 
can not be met and safety can not be provided through a temporary reduction in 
pressure; 
Amend its IMP risk analysis process to ensure risk factors reflect the risk conditions 
on the pipeline segment. The factors an operator must consider include, but are not 
limited to all of the risk factors listed under 5 195.452(e)(l); 
Amend its IMP risk analysis process to ensure that the domiylant causes of risk are 
readily identifiable; 
Amend its IMP risk analysis process to ensure that probability of failure (POF) 
categories are not weighted equally, but instead properly reflect system-specific and 
industry threat history; 
Amend its IMP risk analysis process to ensure that consequence of failure (COF) 
categories weight public safety and environmental considersqtions appropriately and 
that do not over emphasize non-safety considerations such a$ business impacts; 
Amend its IMP risk analysis process to ensure that the application of the risk 
analysis process is to pipeline segments that could affect a HCA and not to pipeline 
sections that have in their length one or more pipeline segmqnt(s) that could affect 
HCAs; 
Amend its IMP risk analysis process to include the application of the risk analysis 
process to all pipeline facilities; 
Amend its IMP preventative and mitigative measures to incllude a determination of 
the likelihood of a pipeline release occurring and how such a release could affect a 
HCA. At a minimum the following risk factors shall be considered; terrain 
surrounding the pipeline segment, including drainage systems such as small streams 
and other smaller waterways that could act as a conduit to the HCA, elevation 
profile, characteristics of the product transported, amount of product that could be 
released, possibility of a spillage in a farm field following the drain tile into a 
waterway, ditches along side a roadway the pipeline crosses, physical support of the 
pipeline segment such as by a cable suspension bridge, exposure of the pipeline to 
operating pressure exceeding established maximum operating pressure; 

23. 
Amend its IMP to include an evaluation of potential preventhive and mitigative 
measures to prevent or minimize the likelihood of a pipeline release. The 
preventative and mitigative measures may include, but are nat limited to; 
implementing damage prevention best practices, better monitoring of CP where 
corrosion is a concern, establishing shorter inspection intervals, installing emergency 
flow restriction devices (EFRDs) on the pipeline segment, modifying the systems 
that monitor pressure and detect leaks, providing additional training to personnel on 
response procedures, conducting drills with local emergency responders and 
adopting other management controls; 
24. 
Amend its IMP preventative and mitigative measures to include a process to evaluate 
the capability of leak detection on their system and a process to modify their leak 
detection capability, as necessary, to protect HCAs. The evaluation process must, at 
least, consider, the following factors-length and size of the pipeline, type of 
product carried, the pipeline's proximity to the HCA, the swiftness of leak detection, 
location of nearest response personnel, leak history, and risk assessment results; 
25. 
Amend its IMP preventative and mitigative measures to include an analytical 
process for determining if an EFRD is needed on a pipeline siegment to protect a 
HCA in the event of a hazardous liquid pipeline release. At a minimum this analysis 
shall consider the following factors-the swiftness of leak detection and pipeline 
shutdown capabilities, the type of commodity carried, the rate of potential leakage, 
the volume that can be released, topography or pipeline profile, the potential for 
ignition, proximity to power sources, location of nearest response personnel, specific 
terrain between the pipeline segment and the HCA, and benefits expected by 
reducing the spill size; 
26. 
Amend its IMP to include processes for the technical justificqtion of the 
reassessment interval for each assessment section. Five years is not a default 
reassessment interval. The reassessment interval must be justified; 
27. 
Amend its IMP to include provisions for notifications to PHMSA for: 1) 
reassessment variances and 2) the use of other technology, as needed; 
28. 
Amend its IMP to include a monitoring and evaluation process for determining the 
program's effectiveness in assessing and evaluating the integrity of each pipeline 
segment in protecting the HCAs; and 
29. 
In complying with each of these items in this Amendment of Procedures section, 
ensure that the required processes and procedures have the fsur characteristics 
identified as (a) through (d) below. The items all relate to the need for Respondent 
to improve its IMP documentation. PHMSA recognizes that a number of program 
elements are still in the development stage, and that documentation will continue to 
evolve as methods are fully developed and defined. However, these procedures as 
well as the management and analytical process guidance used to implement the 
program must be of sufficient detail and specificity to: 

a. 
Clearly articulate the necessary steps to perform each grogram element and 
ensure repeatability, 
b. 
Describe the key input information sources, 
c. 
Define the process output products, their documentation (including the 
justification for decisions), and document retention requirements, and 
d. 
Specify organizational responsibilities for performing key process steps. 
30. 
Submit the amended procedures and technical justifications tq the Director, Western 
Region, PHMSA within 30 days following receipt of this Ordbr Directing 
Amendment. 
The Director may grant an extension of time to comply with any of the required items upon a 
written request timely submitted by Respondent demonstrating good cause for an extension. 
Failure to comply with this Order Directing Amendment may result in the assessment of civil 
penalties of up to $100,000 per violation per day, or in the referral of the case for judicial 
enforcement. 
WARNING ITEM 
The Notice did not propose a civil penalty or corrective action for Item 3(&). Therefore, this is 
considered to be a warning item. Respondent is warned that if it does not take appropriate action 
to correct this item, enforcement will be taken if a subsequent inspection r~veals a violation. 
Under 49 C.F.R. 5 190.215, Respondent has a right to submit a petition for reconsideration of 
this Final Order. The petition must be received within 20 days of Respondent's receipt of this 
Final Order and must contain a brief statement of the issue(s). The filing of the petition 
automatically stays the payment of any civil penalty assessed. All other terms of the order, 
including any required corrective action and amendment of procedures, remain in full effect 
unless the Associate Administrator, upon request, grants a stay. The terms and conditions of this 
Final Order are effective on receipt. 
Date Issued 
iate Administrator 
Pipeline Safety