# MARKWEST RANGER PIPELINE COMPANY, L.L.C. — Warning Letter

- **operation:** document
- **citation:** CPF 220075001W
- **title:** MARKWEST RANGER PIPELINE COMPANY, L.L.C. — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-01-25
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.402(a), 195.404(b), 195.567(c), 195.573(c).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-220075001w.json
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-220075001w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220075001W
**body:**

Warning Letter involving MARKWEST RANGER PIPELINE COMPANY, L.L.C.. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.404(b),  195.567(c),  195.573(c). The case was opened on 2007-01-25 and is reported as closed as of 2007-01-25. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220075001W_Warning Letter_01252007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220075001W/220075001W_Warning%20Letter_01252007.pdf

220075001W_Warning Letter_01252007.pdf

@
U.S. Deportment
of Tronsporfolion
Pipeline ond
Hozqrdous l oledoF SotEly
Admlnlstrqflon
233 Peachtree Street Ste. 600
A$anta. GA 30303
WARNING LETTER
CERTIFIED MAIL. RETURN RECEIPT REOUESTED
January 25,2007
Mr. John Mollenkopf
Senior Vice President and Chief Operations Offrcer
MarkWest Hydrocarbon, Inc.
1515 Arapahoe Street
Tower 2, Suite 700
Denver. CO 80202
cPF 2-2007-5001W
Dear Mr. Mollenkopf:
Between December 5 and December 9,2005, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
inspected your pipeline facilities in Kentucky and West Virginia, and reviewed your operation
and maintenance records in Kenova, West Virginia.
As a result of the inspection, it appears that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the
probable violation(s) are:
1. $f 95.404 Maps and records.
. . . (b) Each operator shall maintain for at least 3 years daily operating records that
indicate-
(1) The discharge pressure at each pump station; and
(2) Any emergency or abnormal operation to which the procedures under
$195.402 appty.
The Maytown pump discharge pressure records have been inconect on several recent
occasions. The pressure chart recorder was 83 psig "off in August, 2004,120 psig low



7
J.
4.
immediately following the November 8,2004lve1 accident, and 25 psig low during this
standard inspection.
$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.
MarkWest Hydrocarbon, Inc (MarkWest) did not follow abandonment procedures in
decommissioning a pipeline segment on lhe 5" pipeline traversing from Flow Station 2l
to Handvalve 2B(approximately 1 mile) in February, 2005. The segment was not filled
with water or inert material as required of abandonment procedures in Operations'
Maintenance, and Emergencies Manual (OM&E) section 7.5.
$195.567 Which pipelines must have test leads and what must I do to install and
maintain the leads?
. , . (c) Maintenance. You must maintain the test lead wires in a condition that
enables you to obtain electrical measurements to determine whether cathodic
protection complies with $ 195.571.
Four conosion control test leads were not maintained on the Transandy Pipeline. Test
leads at station nos. 52g+g5, 684+73, l}6l+42,and 1090+01 have bien missffig since
the October, 2003 survey.
$f95.573 What must I do to monitor external corrosion control?
. . . (c) Rectifiers and other devices. You must electrically check for proper
p.riorttt"tt"L each device in the first column at the frequency stated in the second
column.
Device Check Frequency
Rectifier
Reverse current switch
Diode
Interference bond
whose failure would
jeopardize structural
protection
At least six times
each calendar Yeart
but with interryals
not exceeding 2 %
months



MarkWest did not electrically inspect an interference bond located near the Maytown
extraction facility, whose failure would jeopardize structural protection of a coated
pipeline segment on the Maytown to Ranger Pipeline at Highway 80, between the years
2000 and 2005. This unknown bond was discovered by MarkWest during a 2005 stray
current survey.
Under 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed $100,000
for each violation for each day the violations persists up to a maximum of $1,000,000 for any
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. We advise you to correct the item(s) identified in this letter.
Be advised that failure to do so will result in MarkWest 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 2-2007-500rw.
Sincerely,
JY,{d;L
Linda Daugherty
Director, Southern Region
Pipeline and Hazardous Materials Safety Administration
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