# MARATHON PIPE LINE LLC — Warning Letter **Citation:** CPF 120176005W **Type / status:** enforcement / historical **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** Not stated **Published:** 2017-06-06 CLOSED warning letter citing 195.202. ## Document text Warning Letter involving MARATHON PIPE LINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.202. The case was opened on 2017-06-06 and is reported as closed as of 2017-06-06. Open the official case record for notices, responses, orders, and the latest status. Official case documents: 120176005W_Warning Letter_06062017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176005W/120176005W_Warning%20Letter_06062017.pdf 120176005W_Warning Letter_06062017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176005W/120176005W_Warning%20Letter_06062017_text.pdf 120176005W_Warning Letter_06062017_text.pdf WARNING LETTER OVERNIGHT EXPRESS DELIVERY June 6, 2017 Timothy Aydt, President Marathon Pipe Line LLC 539 South Main Street Findlay, OH 45840 CPF 1-2017-6005W Dear Mr. Aydt: On September 20, 2016; a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code inspected Marathon Pipe Line LLC (Marathon) Harpster – Lima 12” Pipeline construction project and coating operations at Dura-Bond coating mill in Duquesne, Pennsylvania. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are: 1. §195.202 Compliance with specifications or standards. Each pipeline system must be constructed in accordance with comprehensive written specifications or standards that are consistent with the requirements of this part. Marathon failed to store pipe at the Dura-Bond coating mill according to its written specifications for the handling, shipping, receiving, reporting, and storage of pipe. Marathon’s specification Pipe Line Specification for the Handling, Shipping, Receiving, Reporting, and Storage of Pipe - Section 8.6, Rev. 1 dated August 16, 2016 states, “The number of tiers of pipe to be stacked shall be limited to prevent deformation or other damage to the pipe or its coating due to the weight of the pipe. See attached pipe stacking typicals.” Appendix A of the specification requires 12” pipe to be stacked a maximum of seven rows high. CPF 1-2017-6005W During the inspection, the PHMSA inspector noted 12-inch diameter uncoated pipe that was stacked nine rows high and coated pipe that was stacked eight rows high. Pipe at the Dura-Bond coating mill was therefore stacked higher than permitted, per Marathon’s specification. As of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a related series of violations. 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 Marathon being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, please submit all correspondence to Robert Burrough, Acting Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer to CPF 1- 2017-6005W on each document you submit, and whenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original paper copy to the Eastern Region Office. Please 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, Robert Burrough Acting Director, Eastern Region Pipeline and Hazardous Materials Safety Administration 120176005W_Warning Letter_06062017_text Page 2 of 2 ## Provenance - Official: Yes - Source: - Source ID: `phmsa-enforcement` - SHA-256: `a280f8504bb4d024b75768a9c6f631a134fb641a108b00d699d9273d7a7b9828` - Retrieved: 2026-08-20T04:44:44.458Z - Exported: 2026-08-22T23:16:11.379Z - Document slug: `phmsa-enforcement-120176005w` ### Source metadata ```json { "cpf": "120176005W", "operator": "MARATHON PIPE LINE LLC", "region": "Eastern", "pipelineType": "INTRASTATE LIQUID ONSHORE", "caseStatus": "CLOSED", "citedSections": [ "195.202" ], "dataAsOf": "08/04/2026 12PM", "caseDataAsOf": "2026-08-04", "attachmentCount": 2, "attachments": [ { "name": "120176005W_Warning Letter_06062017.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/120176005W/120176005W_Warning%20Letter_06062017.pdf", "bytes": 1255199, "category": "agency_document" }, { "name": "120176005W_Warning Letter_06062017_text.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/120176005W/120176005W_Warning%20Letter_06062017_text.pdf", "bytes": 102407, "category": "agency_document" } ], "extractedAgencyDocumentCount": 1, "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.", "jurisdiction": "US", "operatorName": "MARATHON PIPE LINE LLC" } ```