# MARATHON ASHLAND PIPE LINE LLC — Notice of Probable Violation

**Citation:** CPF 320065031  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2006-03-28

CLOSED notice of probable violation citing 195.567(c), 195.573(a)(1).

## Document text

Notice of Probable Violation involving MARATHON ASHLAND PIPE LINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.567(c),  195.573(a)(1). The case was opened on 2006-03-28 and is reported as closed as of 2006-11-06. Proposed civil penalty: $6,000. Assessed civil penalty: $6,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320065031_Final Order_07102006.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320065031/320065031_Final%20Order_07102006.pdf

320065031_final order_07102006_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320065031/320065031_final%20order_07102006_text.pdf

320065031_final order_07102006_text.pdf

U 5 Department
of rransportation
Pipeline and
Hazardous Materials Safety
Administration
400 Seventh Sneer, S W
Washington, D C 20590
JUL l 0
Mr Craig 0 Pierson
Vice President, Operations
Marathon Pipe Line, L L C
539 South Main Street
Findlay, OH 45840-3295
Re CPF No 3-2006-5031
Dear Mr Pierson
Enclosed is the Final Order issued by the Associate Administrator for Pipehne Safety in
the above-referenced case It makes findings of violation and assesses a civil penalty of
$6, 000 The penalty payment terms are set forth in the Final Order This enforcement action
closes automatically upon payment Your receipt of the Fmal Order constitutes service of that
document under 49 C F R Ir' 190 5
Sincerely
James Reynolds
Pipehne Comphance Registry
Office of Pipeline Safety
Enclosure
cc Ivan A Huntoon
Director, Central Region, PHP-300
CERTIFIED MAIL — RETURN RECEIPT RE UESTED



DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARD/US MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
)
In the Matter of )
)
Marathon Pipe Line, L. L. C.
, )
)
Respondent )
CPF No. 3-2006-5031
FINAL ORDER
On Apnl 25-29 and May 2-6, 2005, pursuant to 49 U S C ) 60117, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), mspected Respondent's
records in Lima, Heath and Sparta, Ohio, and Respondent's facilities located wittun the states of
Ohio, West Virginia, and Pennsylvama As a result, the Director, Central Region, PHMSA,
issued to Respondent a Notice of Probable Violation and Proposed Civil Penalty (Notice) The
Notice proposed finding that Respondent had committed violations of 49 C F R Part 195 and
proposed assessing a civil penalty of $6, 000 for the alleged violations
Respondent responded to the Notice by letter dated Apnl 25, 2006 Respondent did not contest
the allegations and agreed to pay the proposed civil penalties
FINDINGS OF VIOLATIONS
In its Response, Respondent did not contest the alleged violations in the Notice
Pursuant to 49 C F R $ 190 213 and 49 U S C $ 60122, I find that Respondent violated the
following sections of 49 C F R Part 195, as more fully described in the Notice
49 C F R $ 195 567(c) (Notice Item 1) — failing to maintiun the specified cathodic
protection test lead wires, and
49 C F R $ 195 573(a)(1) (Notice Item 2) — faihng to conduct annual cathodic protection
testing at the specified test stations
These finding of violation will be considered prior offenses in any subsequent enforcement
action taken agamst Respondent



ASS SSMENT OF PENALTY
Under 49 U S C II 60122, Respondept is sub)ect to a civil penalty not to exceed $100, 000 per
violation for each day of the vholathoth up to a maximum of $1, 000, 000 for any related senes of
violations
49 U S C Il 60122 and 49 C F R I'h 190 225 require that, in determining the amount of the civil
penalty, I consider the follovnng cntena nature, circumstances, and gravity of the violation,
degree of Respondent's culpabihty, history of Respondent's pnor offenses, Respondent's abihty
to pay the penalty, good faith by Respondent in attempting to achieve comphance, the effect on
Respondent's abihty to continue in business, and such other matters as)ustice may require
In regard to Item I, the Notice proposed a civil penalty of $4, 000 for Respondent's fiulure to
mamtahn cathodic protection test lead wires Maintaining cathodic protection test lead wires is
necessary to obtain electncal measurements for external corrosion control We acknowledge
Respondent's intention to take appropnate action to prevent the occurrence of missed or un-
rephured test stations hn the future Respondent, however, has presented no information that
would warrant a reduction in the civil penalty amount proposed hn the Notice for this violation
Accordingly, I assess Respondent a civil penalty of $4, 000 for violating 49 C F R $ 195 567(c)
In regard to Item 2, the Notice proposed a civd penalty of $2, 000 for Respondent's fadure to
conduct annual test readings on protected pipehnes Conducting annual test readmgs on
protected pipehnes is important to moiutor external corrosion Respondent has presented no
information that would warrant a reduction in the civil penalty amount proposed hn the Notice for
this violation Accordingly, I assess Respondent a civil penalty of $2, 000 for vholatmg C F R
$195 573(a)(1)
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent a total civil penalty of $6, 000 Respondent has the abihty to pay tlus penalty without
adversely affecting its abihty to continue in business
Payment of the civil penalty must be made whttun 20 days of service Payment may be made by
sending a certified check or money order (contaming the CPF Number for tins case) payable to
"U S Department of Transportathohh" to the Federal Aviation Administration, Mike Monroney
Aeronautical Center, Financial Operations Division (AMZ-300), P 0 Box 25082, Oldahoma
City, OK 73125
Federal regulations (49 C F R $ 89 21(b)(3)) also permit this payment to be made by wire
transfer, through the Federal Reserve Commuhucations System (Fedwhre), to the account of the
U S Treasury Detailed instructions are contiuned m the enclosure Questions concerhung wire
transfers should be directed to Financial Operations Division (AMZ-300), Federal Aviation
Admuustration, Mike Monroney Aeronautical Center, P 0 Box 25082, Oklahoma City, OK
73125, (405) 954-8893
Failure to pay the $6, 000 civil penalty will result in accrual of mterest at the current annual rate
inaccordance with 31 US C Il 3717, 31 C FR Il 901 9and49 C FR $ 8923 Pursuantto



those same authonties, a late penalty charge of stx percent (6%) per annum will be charged if
payment is not made within 110 days of service Furthermore, failure to pay the civil penalty
may result in referral of the matter trt the Attorney General for appropnate action m a Uruted
States Distnct Court
Under 49 C F R $ 190 215, Respondent has a nght to submit a Petition for Reconsideration of
this Final Order The petition must be received wtttun 20 days of Respondent's receipt of tins
Final Order and must contain a bnef statement of the issue(s) The fihng of the petthon
automatically stays the payment of any civd penalty assessed However if Respondent submits
payment for the civil penalty, the Fmal Order becomes the final administrative decision and the
nght to petition for reconsideration is waived The terms and conditions of this Fmal Order are
effective on receipt
Jt)h 1 0
Date Issued
St ce Ge d
Ass ate Administrator
for ipelme Safety

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/320065031>
- Source ID: `phmsa-enforcement`
- SHA-256: `f03ee28b6fead10ebaf47c426de28a133554db364141a64ff70a76c4b42106d8`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-24T22:32:48.944Z
- Document slug: `phmsa-enforcement-320065031`

### Source metadata

```json
{
  "cpf": "320065031",
  "operator": "MARATHON ASHLAND PIPE LINE LLC",
  "region": "Central",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.567(c)",
    "195.573(a)(1)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "320065031_Final Order_07102006.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/320065031/320065031_Final%20Order_07102006.pdf",
      "bytes": 121295,
      "category": "agency_document"
    },
    {
      "name": "320065031_final order_07102006_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/320065031/320065031_final%20order_07102006_text.pdf",
      "bytes": 129248,
      "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 ASHLAND PIPE LINE LLC"
}
```
