# COUNTRYMARK REFINING AND LOGISTICS, LLC — Warning Letter

**Citation:** CPF 320135031W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2013-10-18

CLOSED warning letter citing 195.573(e).

## Document text

Warning Letter involving COUNTRYMARK REFINING AND LOGISTICS, LLC. PHMSA's enforcement data identifies the cited regulation as 195.573(e). The case was opened on 2013-10-18 and is reported as closed as of 2013-10-18. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320135031W_Warning Letter_10182013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320135031W/320135031W_Warning%20Letter_10182013.pdf

320135031W_Warning Letter_10182013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320135031W/320135031W_Warning%20Letter_10182013_text.pdf

320135031W_Warning Letter_10182013_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
October 18, 2013
Joe Sudholt, Vice President
CountryMark Refining and Logistics, LLC
1200 Refinery Road
Mt. Vernon, IN 47620
CPF 3-2013-5031W
Dear Mr. Sudholt:
On November 27-30, 2012, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
facilities in Mt Vernon, Indiana and rural Illinois and rural southwestern Indiana.
As a result of the inspection, it appears that CountryMark Refining and Logistics, LLC
(CountryMark) has committed a probable violation of the Pipeline Safety Regulations, Title
49, Code of Federal Regulations. The items inspected and the probable violation is:
1. §195.573 What must I do to monitor external corrosion control?
(e) Corrective action. You must correct any identified deficiency in corrosion
control as required by Sec. 195.401(b). However, if the deficiency involves a
pipeline in an integrity management program under Sec. 195.452, you must
correct the deficiency as required by Sec. 195.452(h).
CountryMark did not correct identified deficiencies within a reasonable time on its
Clay City, IL to Johnsonville, IL pipeline segment near station 790+21 after
discovery of deficiencies identified from the external corrosion control monitoring
required by 49 CFR §195.573(a)(1). Monitoring was conducted in calendar years
2011 and 2012 and identified a section of pipeline near station 790+21 at a crossing
with a foreign pipeline where the pipeline was not adequately protected from
corrosion. Repairs and/or correction of the cathodic protection on the pipeline



system were not completed at the time of the PHMSA inspection in November
2012. Information was submitted to PHMSA demonstrating that repairs were
completed on September 5, 2013 with the replacement of 2.25 miles of pipe.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a
related series of violations. For violations occurring prior to January 4, 2012, the maximum
penalty may not exceed $100,000 per violation per day, with a maximum penalty not to
exceed $1,000,000 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.
No reply to this letter is required. If you choose to reply, in your correspondence please
refer to CPF 3-2013-5031W. 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,
Linda Daugherty
Director, Central Region
Pipeline and Hazardous Materials Safety Administration
2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/320135031W>
- Source ID: `phmsa-enforcement`
- SHA-256: `63e3574aa6ba319690de7acddcaeb2f6e3d75c6f33a8b11acb6d0e372dc68b40`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T05:58:04.784Z
- Document slug: `phmsa-enforcement-320135031w`

### Source metadata

```json
{
  "cpf": "320135031W",
  "operator": "COUNTRYMARK REFINING AND LOGISTICS, LLC",
  "region": "Central",
  "pipelineType": "INTERSTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.573(e)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "320135031W_Warning Letter_10182013.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/320135031W/320135031W_Warning%20Letter_10182013.pdf",
      "bytes": 129289,
      "category": "agency_document"
    },
    {
      "name": "320135031W_Warning Letter_10182013_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/320135031W/320135031W_Warning%20Letter_10182013_text.pdf",
      "bytes": 7427,
      "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": "COUNTRYMARK REFINING AND LOGISTICS, LLC"
}
```
