# MARATHON PIPE LINE LLC — Warning Letter **Citation:** CPF 32022038WL **Type / status:** enforcement / historical **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** Not stated **Published:** 2022-03-08 CLOSED warning letter citing 195.410(a)(2)(ii). ## Document text Warning Letter involving MARATHON PIPE LINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.410(a)(2)(ii). The case was opened on 2022-03-08 and is reported as closed as of 2022-03-08. Open the official case record for notices, responses, orders, and the latest status. Official case documents: 32022038WL_Operator Response to Notice_06132022_(21-201424).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022038WL/32022038WL_Operator%20Response%20to%20Notice_06132022_(21-201424).pdf 32022038WL_Warning Letter_03082022_(21-201424).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022038WL/32022038WL_Warning%20Letter_03082022_(21-201424).pdf 32022038WL_Warning Letter_03082022_(21-201424)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32022038WL/32022038WL_Warning%20Letter_03082022_(21-201424)_text.pdf 32022038WL_Warning Letter_03082022_(21-201424)_text.pdf WARNING LETTER VIA ELECTRONIC MAIL TO: SMLyon@MarathonPetroleum.com and MLBailey@MarathonPetroleum.com March 8, 2022 Shawn M. Lyons, President Marathon Pipe Line, LLC 539 South Main Street, Findlay, OH 45840 CPF 3-2022-038-WL Dear Mr. Lyons: From February 17, 2021, through November 23, 2021, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Marathon Northwest Products system facilities located in Oregon and Washington State. This inspection also reviewed associated plans, procedures, and records, located in Findley, Ohio, Oregon, and Washington State. As a result of the inspection, it is alleged that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable violation is: 1. § 195.410 Line Markers. (a) Except as provided in paragraph (b) of this section, each operator shall place and maintain line markers over each buried pipeline in accordance with the following: (1) . . . . (2) The marker must state at least the following on a background of sharply contrasting color: (i) . . . . (ii) The name of the operator and a telephone number (including area code) where the operator can be reached at all times. Marathon failed to maintain line markers as required by § 195.410(a)(2)(ii), by not updating the name of the operating company from Tesoro to Marathon Pipe Line, LLC. The PHMSA inspection onsite was completed in August of 2021 giving Marathon sufficient time to update the operator name information. Tesoro known at the time of purchase as Andeavor was purchased by Marathon Pipe Line, LLC on October 1, 2018. To meet the requirements of §195.410 (a)(2)(ii), the operator name listed on the markers should be updated with the current pipeline operator’s name. Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed $2,090,022 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 Pipe Line, LLC being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 3-2022-038-WL. 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, Gregory A. Ochs Director, Central Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Ms. Mandy Bailey, Compliance, Marathon, MLBailey@MarathonPetroleum.com 2 ## Provenance - Official: Yes - Source: - Source ID: `phmsa-enforcement` - SHA-256: `a50c0828bcfac3513454358f3b9c9226d4508e5aa7b4b2aaa4d3100e78f58802` - Retrieved: 2026-08-20T04:44:44.458Z - Exported: 2026-08-22T11:16:06.367Z - Document slug: `phmsa-enforcement-32022038wl` ### Source metadata ```json { "cpf": "32022038WL", "operator": "MARATHON PIPE LINE LLC", "region": "Central", "pipelineType": "INTERSTATE LIQUID", "caseStatus": "CLOSED", "citedSections": [ "195.410(a)(2)(ii)" ], "dataAsOf": "08/04/2026 12PM", "caseDataAsOf": "2026-08-04", "attachmentCount": 3, "attachments": [ { "name": "32022038WL_Operator Response to Notice_06132022_(21-201424).pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/32022038WL/32022038WL_Operator%20Response%20to%20Notice_06132022_(21-201424).pdf", "bytes": 552282, "category": "party_submission" }, { "name": "32022038WL_Warning Letter_03082022_(21-201424).pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/32022038WL/32022038WL_Warning%20Letter_03082022_(21-201424).pdf", "bytes": 250635, "category": "agency_document" }, { "name": "32022038WL_Warning Letter_03082022_(21-201424)_text.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/32022038WL/32022038WL_Warning%20Letter_03082022_(21-201424)_text.pdf", "bytes": 89259, "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" } ```