MPLX LP — Notice of Amendment

party submissionOfficial PDF12023031NOA_Operator Withdrawal of Hearing Request_08042023_(22-233210).pdf#

12023031NOA_Closure Letter_08112023_(22-233210)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: GSFloerke@marathonpetroleum.com August 11, 2023 Mr. Gregory Floerke Executive Vice President, Gathering and Processing MPLX LP 1515 Arapahoe Street, Tower 1 Suite 1600 Denver, Colorado 80202 CPF 1-2023-031-NOA Dear Mr. Floerke: From August 8, 2022, to October 21, 2022, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected MPLX LP’s (MPLX) procedures in Denver, Colorado. As a result of the inspection, MPLX was issued a Notice of Amendment on April 13, 2023 requiring MPLX to amend certain aspects of its procedures. MPLX submitted its amended procedures on June 13, 2023. On August 1, 2023, PHMSA met with MPLX to address its concerns regarding inadequacies in the amended procedures. MPLX submitted further amended procedures on August 4, 2023. My staff reviewed the further amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#

12023031NOA_Operator Resp to Notice and ReqForHearing_06132023_(22-233210).pdf, page 1Official PDF1515 Arapahoe Street, Tower 1, Suite 1600 Denver, CO 80202 June 13, 2023 Via E-mail (robert.burrough@dot.gov) and UPS Mr. Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration 840 Bear Tavern Road, Suite 300 West Trenton, NJ 08628 CPF 1-2023-031-NOA Dear Mr. Burrough: In response to PHMSA’s NOA correspondence dated April 13, 2023, MPLX responds to PHMSA’s alleged inadequacies within MPLX’s plans or procedures.1 PHMSA alleged four separate deficiencies in MPLX’s Operations, Maintenance & Emergency Manual-Liquids Program, dated 06/07/21 (OME). MPLX summarizes PHMSA’s allegation and MPLX’s response below: 1. MPLX’s procedures failed to include a process for verifying that its supervisors maintain a thorough knowledge of that portion of the corrosion control procedures established under § 195.402(c)(3) for which they are responsible for ensuring compliance, in accordance with§ 195.555. MPLX must revise its procedures to address this requirement. MPLX agrees to update its OME. Please see Attachment 1. This will require CP Supervisors to be part of updating and reviewing the CP procedures and to demonstrate their knowledge of those procedures. 2. MPLX’s procedures failed to include processes for taking necessary action, such as an emergency shutdown or pressure reduction, to minimize the volume released from any section of a pipeline system in the event of a failure, in accordance with § 195.402(e)(4). MPLX must revise its procedures to address this requirement. MPLX disagrees with PHMSA’s position. The Liquid OME Section 7.17.4 states, “If necessary, shut down or reduce pressure to minimize hazards to protect life, environment, and property.” Please see Attachment 2, highlighting the processes MPLX has in place for meeting this regulatory requirement. The specific examples of when to protect life, environment, and 1 PHMSA extended the deadline for MPLX to respond to the NOA until June 13, 2023, in a letter dated May 26, 2023.#

12023031NOA_Operator Resp to Notice and ReqForHearing_06132023_(22-233210).pdf, page 2property are noted in the following areas: 3.5.1 Safety-Related Conditions. "Any Safety-Related Condition that could lead to an imminent hazard and causes (either directly or indirectly by remedial action of MPLX), for purposes other than abandonment, a 20 percent or more reduction in operating pressure or shutdown of pipeline operation." 7.16.1 Pipeline AOCs list multiple situations when MPLX reduces pressure or shuts down pipelines. This substantially complies with the regulatory requirements for this section and MPL does not believe any update is necessary. 3. MPLX failed to include instructions in its written procedures for personnel to recognize conditions that potentially may be safety-related conditions in accordance with § 195.402(f). MPLX must revise its procedures to address this requirement. MPLX disagrees with PHMSA's position. Each year during the MPLX OME Review, AOCs and SRCs are reviewed by MPLX Compliance and Operations. Section 7.16.1 of MPLX's OME outlines all AOCs, potential SRCs, and the specific form used to document SRCs (FRM- 101). When AOCs in Table 7.16.1 occur, a MAPLine and/or Stop Help Start call will be initiated These processes bring all necessary parties on a call to discuss the identified AOC/SRC issues. Please see Attachment 3, which highlights what conditions may constitute a Safety Related Condition. MPLX has substantially complied with the regulatory requirements here. Notwithstanding the foregoing and without waiving any rights, MPLX will change the header of Section 7.16.1 to state: "Pipeline AOCs & SRCs." MPLX's procedures failed to require and include a process to verify that supervisors are knowledgeable of emergency response procedures for which they are responsible in accordance with § 195.403 (c). MPLX must revise its procedures to address this requirement. MPLX to update Section 7.18.1 of its OEM Procedures. Please see Attachment 4, appended to this letter. MPLX hopes that this response satisfies PHMSA's concerns regarding its OME procedures. However, should PHMSA continue to believe MPLX's OME to be deficient in any way, MPLX would hereby request a hearing to adjudicate any remaining issues. Please don't hesitate to contact me at (303) 531-9529 or TMinutillo@MPLX.com. Sincerely, Tony Minutille Tony Minutillo MPLX LP Compliance Manager Enclosure(s)#

12023031NOA_Notice of Amendment_04132023_(22-233210)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY April 13, 2023 Mr. Gregory Floerke Executive Vice President, Gathering and Processing MPLX LP 1515 Arapahoe Street, Tower 1 Suite 1600 Denver, Colorado 80202 CPF 1-2023-031-NOA Dear Mr. Floerke: From August 8, 2022 through October 21, 2022 a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) conducted an inspection of the procedures of MPLX, LP (MPLX), in Denver, Colorado. 1 As a result of the inspection, PHMSA has identified the apparent inadequacies found within MPLX’s plans or procedures. The items inspected and the inadequacies are described below. 1. § 195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at 1 At the time of the inspection, the procedures cited in this Notice of Amendment applied to three MPLX subsidiaries covered during this inspection: PHMSA Operator Identification Number (OPID) 39920 for MarkWest Liberty Ethane Pipeline, L.L.C. under inspection unit number 89319; OPID 39941 MarkWest Utica EMG, L.L.C. under inspection unit number 82542; and, OPID 39922 for Markwest Liberty NGL Pipeline, L.L.C. under inspection unit number 89319. MPLX has recently consolidated some of its OPIDs under its OPID 40149 MPLX LP.#

12023031NOA_Notice of Amendment_04132023_(22-233210)_text.pdf, page 2locations where operations and maintenance activities are conducted. MPLX’s procedures for maintenance and normal operations were inadequate to assure safe operation of a pipeline facility. Specifically, MPLX’s Operations, Maintenance & Emergency Manual-Liquids Program, dated 06/07/21 (OME) failed to include a process for verifying that its “supervisors maintain a thorough knowledge of that portion of the corrosion control procedures established under § 195.402(c)(3) for which they are responsible for insuring compliance”, in accordance with § 195.5552 . During the inspection, PHMSA requested MPLX's procedures regarding corrosion control supervisor requirements pursuant to § 195.555. MPLX provided its Operating Standard- Corrosion Control Governing Standard OPS-STD-0017, dated 4/1/21 (Corrosion Standard). Section 4.2 of the Corrosion Standard requires, in part, that management and supervisory personnel whose responsibilities relate to direct supervision of persons responsible for implementation of MPLX's Corrosion Control Program are required to possess and maintain a thorough knowledge of the MPLX’s Corrosion Control Program and elements for which the supervisor is responsible. Section 4.2 also requires MPLX personnel who qualify as the supervisor for a Regional Corrosion Control Team must hold NACE certifications or be part of a plan to attain the certification for the specified area of corrosion control expertise. However, the Corrosion Standard failed to include any procedure or details on how MPLX actually verifies that supervisors maintain a thorough knowledge of its corrosion control procedures. Therefore, MPLX’s procedures failed to include a process for verifying that its supervisors maintain a thorough knowledge of that portion of the corrosion control procedures established under § 195.402(c)(3) for which they are responsible for insuring compliance, in accordance with § 195.555. MPLX must revise its procedures to address this requirement. 2. § 195.402 Procedural manual for operations, maintenance, and emergencies. (a) … (e) Emergencies. The manual required by paragraph (a) of this section must include procedures for the following to provide safety when an emergency condition occurs: (1) … (4) Taking necessary action, such as emergency shutdown or pressure reduction, to minimize the volume of hazardous liquid or carbon dioxide that is released from any section of a pipeline system in the event of a failure. MPLX’s procedures for emergencies were inadequate to ensure safe operation of a pipeline facility. Specifically, MPLX’s Operations, Maintenance & Emergency Manual-Liquids Program, dated 06/07/21 (OME) failed to include processes for taking necessary action, such as an 2 § 195.555 What are the qualifications for supervisors? You must require and verify that supervisors maintain a thorough knowledge of that portion of the corrosion control procedures established under § 195.402(c)(3) for which they are responsible for insuring compliance.#

12023031NOA_Notice of Amendment_04132023_(22-233210)_text.pdf, page 3emergency shutdown or pressure reduction, to minimize the volume released from any section of a pipeline system in the event of a failure. During the inspection, PHMSA requested MPLX’s procedures regarding the § 195.402(e)(4) requirements. MPLX provided the OME. Section 7.17.4 requires, in part, that if necessary, MPLX personnel must shut down or reduce pipeline pressure to minimize hazards to protect life, environment, and property. When PHMSA requested additional procedures or information related to how this process would be carried out, MPLX was unable to provide any further documentation. Section 7.17 also does not explain in what situations MPLX requires it “necessary” to shut down a pipeline or reduce pressures. Subsequent to the inspection, MPLX stated that its Liquid OME Section 7.17.4 clearly states the actions to control a release. However, the OME did not provide any processes for how these actions would be carried out. Therefore, MPLX’s procedures failed to include processes for taking necessary action; such as an emergency shutdown or pressure reduction, to minimize the volume released from any section of a pipeline system in the event of a failure, in accordance with § 195.402(e)(4). MPLX must revise its procedures to address this requirement. 3. § 195.402 Procedural manual for operations, maintenance, and emergencies. (a) … (f) Safety-related condition reports. The manual required by paragraph (a) of this section must include instructions enabling personnel who perform operation and maintenance activities to recognize conditions that potentially may be safety-related conditions that are subject to the reporting requirements of § 195.55. MPLX’s procedures for safety related condition reports were inadequate. Specifically, MPLX’s Operations, Maintenance & Emergency Manual-Liquids Program, dated 06/07/21 (OME) failed to include instructions enabling personnel who perform operation and maintenance activities to recognize conditions that potentially may be safety-related conditions (SRCs) that are subject to the reporting requirements of § 195.55. During the inspection, the PHMSA inspector requested MPLX’s procedure regarding recognizing SRCs. MPLX provided the OME Section 3. Section 3 presented MPLX’s definition of SRCs, which merely matched the list of SRCs found in § 195.55(a), but per § 195.402(f) contained no instructions enabling MPLX personnel to be able to recognize such SRCs. Subsequent to the inspection, MPLX stated its Liquid OME Sections 3.5.1 and 7.16.1 clearly show how a MPLX employee can recognize and respond to a potential safety related condition. However, the OME Section 3.5.1 lacked any criteria and/or examples that would allow MPLX personnel to differentiate between what is and what is not a potential safety-related condition. Furthermore, Section 7.16.1 was titled Pipeline AOCs and was unrelated to SRCs. When the PHMSA inspector re-requested information related to the § 195.55, MPLX was unable to clarify or demonstrate further information.#

12023031NOA_Notice of Amendment_04132023_(22-233210)_text.pdf, page 44. Therefore, MPLX failed to include instructions in its written procedures for personnel to recognize conditions that potentially may be safety-related conditions in accordance with § 195.402(f). MPLX must revise its procedures to address this requirement. § 195.403 Emergency response training. (a) ... (c) Each operator shall require and verify that its supervisors maintain a thorough knowledge of that portion of the emergency response procedures established under 195.402 for which they are responsible to ensure compliance. MPLX’s procedures for emergency response training were inadequate to ensure safe operation of a pipeline facility. Specifically, MPLX’s Operations, Maintenance & Emergency Manual-Liquids Program, dated 06/07/21 (OME) failed to require and include a process to verify that supervisors be knowledgeable of emergency response procedures for which they are responsible for per the requirements of § 195.403(c). During the inspection, PHMSA requested MPLX’s procedures regarding emergency response supervisor training. MPLX provided the OME. Section 7.18.1 requires in part, that MPLX will require and verify that its supervisors who are responsible for emergency action have the present MPLX emergency procedures. The OME failed to include adequate details on how having a copy of the latest edition of MPLX emergency procedures is used to verify supervisors are knowledgeable of the emergency response procedures. Subsequent to the inspection, MPLX stated that its Liquid OME Section 7.18.1 clearly states the requirements that supervisors have knowledge of the Emergency Response Plan. However, the OME did not provide any processes on how MPLX actually verifies that supervisors are maintaining knowledge of the emergency response procedures for which they are responsible. Therefore, MPLX's procedures failed to require and include a process to verify that supervisors are knowledgeable of emergency response procedures for which they are responsible in accordance with § 195.403(c). MPLX must revise its procedures to address this requirement. Response to this Notice Please refer to this document and note the response options. 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice#

12023031NOA_Notice of Amendment_04132023_(22-233210)_text.pdf, page 5without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that MPLX LP maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 1-2023-031-NOA and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings#