{"operation":"document","citation":"CPF 120176005W","title":"MARATHON PIPE LINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-06-06","effective_on":null,"summary":"CLOSED warning letter citing 195.202.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120176005w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120176005w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120176005w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120176005W","body":"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.\n\nOfficial case documents:\n\n120176005W_Warning Letter_06062017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176005W/120176005W_Warning%20Letter_06062017.pdf\n\n120176005W_Warning Letter_06062017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120176005W/120176005W_Warning%20Letter_06062017_text.pdf\n\n120176005W_Warning Letter_06062017_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nJune 6, 2017\nTimothy Aydt, President\nMarathon Pipe Line LLC\n539 South Main Street\nFindlay, OH 45840\nCPF 1-2017-6005W\nDear Mr. Aydt:\nOn September 20, 2016; a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United\nStates Code inspected Marathon Pipe Line LLC (Marathon) Harpster – Lima 12” Pipeline\nconstruction project and coating operations at Dura-Bond coating mill in Duquesne, Pennsylvania.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolations are:\n1. §195.202 Compliance with specifications or standards.\nEach pipeline system must be constructed in accordance with comprehensive written\nspecifications or standards that are consistent with the requirements of this part.\nMarathon failed to store pipe at the Dura-Bond coating mill according to its written specifications\nfor the handling, shipping, receiving, reporting, and storage of pipe.\nMarathon’s specification Pipe Line Specification for the Handling, Shipping, Receiving,\nReporting, and Storage of Pipe - Section 8.6, Rev. 1 dated August 16, 2016 states, “The number\nof tiers of pipe to be stacked shall be limited to prevent deformation or other damage to the pipe\nor its coating due to the weight of the pipe. See attached pipe stacking typicals.” Appendix A of\nthe specification requires 12” pipe to be stacked a maximum of seven rows high.\n\n\n\nCPF 1-2017-6005W\nDuring the inspection, the PHMSA inspector noted 12-inch diameter uncoated pipe that was\nstacked nine rows high and coated pipe that was stacked eight rows high. Pipe at the Dura-Bond\ncoating mill was therefore stacked higher than permitted, per Marathon’s specification.\nAs of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil\npenalty not to exceed $209,002 per violation per day the violation persists up to a maximum of\n$2,090,022 for a related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement action\nor penalty assessment proceedings at this time. We advise you to correct the item identified in this\nletter. Failure to do so will result in Marathon being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, please submit all correspondence to\nRobert Burrough, Acting Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103,\nWest Trenton, NJ 08628. Please refer to CPF 1- 2017-6005W on each document you submit, and\nwhenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed\nto robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original\npaper copy to the Eastern Region Office.\nPlease be advised that all material you submit in response to this enforcement action is subject to\nbeing made publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120176005W_Warning Letter_06062017_text Page 2 of 2","truncated":false,"body_characters":4335}