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

- **operation:** document
- **citation:** CPF 220115003W
- **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:** 2011-03-14
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.507(b), 195.571.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-220115003w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-220115003w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220115003W
**body:**

Warning Letter involving MARKWEST RANGER PIPELINE COMPANY, L.L.C.. PHMSA's enforcement data identifies the cited regulations as 195.507(b),  195.571. The case was opened on 2011-03-14 and is reported as closed as of 2011-03-14. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220115003W_warning letter_03142011.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115003W/220115003W_warning%20letter_03142011.pdf

220115003W_warning letter_03142011_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220115003W/220115003W_warning%20letter_03142011_text.pdf

220115003W_warning letter_03142011_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
March 14, 2011
John C. Mollenkopf,
Sr. Vice President, COO
Markwest Energy Appalachia, LLC
1515 Arapahoe Street, Tower 2, Suite 700
Denver, CO 80202
CPF 2-2011-5003W
Dear Mr. Mollenkopf:
Between November 29 and December 3, 2010, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) inspected Markwest Energy Appalachia, LLC
(Markwest) procedures and records in Ashland, Kentucky and your pipeline facilities located
in Kentucky and West Virginia, pursuant to Chapter 601 of 49 United States Code.
As a result of the inspection, it appears that Markwest has committed probable violations of
the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected
and the probable violations are:
1. § 195.507 Recordkeeping.
Each operator shall maintain records that demonstrate compliance with this
subpart.
… (b) Records supporting an individual's current qualification shall be
maintained while the individual is performing the covered task. Records of prior
qualification and records of individuals no longer performing covered tasks shall
be retained for a period of five years.
Markwest did not maintain records that demonstrated compliance with Part 195,
Subpart G - Qualification of Pipeline Personnel. Markwest hired contract welders to
perform welding (an OQ covered task) on the Transandy pipeline as part of the valve
reconfiguration that was completed in 2008. At the time of the inspection, Markwest
did not provide records of prior qualification or records demonstrating how it ensured
through evaluation that the contract welders performing covered tasks were OQ
qualified.



2. § 195.571 What criteria must I use to determine the adequacy of cathodic
protection?
Cathodic protection required by this Subpart must comply with one or more of
the applicable criteria and other considerations for cathodic protection contained
in paragraphs 6.2 and 6.3 of NACE SP 0169 (incorporated by reference, see
§195.3).
Markwest’s Operations, Maintenance and Emergencies Manual (OM&E) did not
require compliance with the applicable criteria in NACE SP0169–2007. The
Markwest OM&E incorrectly referenced “the most current edition of the National
Association of Corrosion Engineers (NACE) Standard RP0169-2002.” The federal
pipeline safety regulations incorporate by reference NACE SP0169–2007, not the
current version and not the 2002 edition.
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 violation 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. 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 2-2011-5003W. 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,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region
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