# MARKWEST RANGER PIPELINE COMPANY, L.L.C. — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 220125007
- **title:** MARKWEST RANGER PIPELINE COMPANY, L.L.C. — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2012-06-19
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.440(a), 195.440(b), 195.440(i).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-220125007.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-220125007
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/220125007
**body:**

Notice of Probable Violation involving MARKWEST RANGER PIPELINE COMPANY, L.L.C.. PHMSA's enforcement data identifies the cited regulations as 195.440(a),  195.440(b),  195.440(i). The case was opened on 2012-06-19 and is reported as closed as of 2013-07-23. Proposed civil penalty: $17,600. Assessed civil penalty: $17,600. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220125007_closure letter_07232013_.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125007/220125007_closure%20letter_07232013_.pdf

220125007_closure letter_07232013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125007/220125007_closure%20letter_07232013_text.pdf

220125007_Corrected Final Order_04182013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125007/220125007_Corrected%20Final%20Order_04182013.pdf

220125007_Corrected Final Order_04182013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125007/220125007_Corrected%20Final%20Order_04182013_text.pdf

220125007_NOPV_PCP_PCO_06192012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125007/220125007_NOPV_PCP_PCO_06192012.pdf

220125007_NOPV_PCP_PCO_06192012_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125007/220125007_NOPV_PCP_PCO_06192012_text.pdf

220125007_Operator Response and Request for Hearing_08202012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220125007/220125007_Operator%20Response%20and%20Request%20for%20Hearing_08202012.pdf

220125007_closure letter_07232013_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 23, 2013
Mr. John Mollenkopf
Senior Vice President, Chief Operations Officer
MarkWest Ranger Pipeline Company
1515 Arapahoe Street, Tower 2, Suite 700
Denver, CO 80202-2126
CPF 2-2012-5007
Dear Mr. Mollenkopf:
On April 18, 2013, the Pipeline and Hazardous Materials Safety Administration (PHMSA),
Office of Pipeline Safety (OPS) issued to MarkWest Ranger Pipeline Company (MarkWest) a
Final Order in the above-referenced case. The Final Order included an assessed civil penalty
and a Compliance Order (CO).
On July 22, 2013, the OPS Southern Region received MarkWest’s written response to the
Compliance Order. Based on our review of this response and our confirmation that
MarkWest has paid the civil penalty, we have determined that MarkWest has complied with
the terms of the Final Order. This case is now closed and no further action is necessary with
respect to the matters involved in this case.
Please be advised that this letter refers only to the above referenced order (CPF 2-2012-5007)
and not to any other OPS cases, if any.
Thank you for your cooperation in this matter.
Sincerely,
Wayne T. Lemoi
Director, Office of Pipeline Safety
PHMSA Southern Region

220125007_Corrected Final Order_04182013_text.pdf

APRIL 18, 2013
Mr. John Mollenkopf
Senior Vice President, Chief Operations Officer
MarkWest Ranger Pipeline Company, LLC
1515 Arapahoe Street, Tower 2, Suite 700
Denver, CO 80202-2126
Re: CPF No. 2-2012-5007
Dear Mr. Mollenkopf:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $17,600, and specifies actions that need to be taken by
MarkWest Ranger Pipeline Company, LLC to comply with the pipeline safety regulations. The
penalty payment terms are set forth in the Final Order. When the civil penalty has been paid and
the terms of the compliance order completed, as determined by the Director, Southern Region,
this enforcement action will be closed. Service of the Final Order by certified mail is deemed
effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Christopher Rimkus, Associate Counsel
1515 Arapahoe St. Tower 1, Suite 1600, Denver, CO 80202-2137
Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS
Mr. Wayne Lemoi, Director, Southern Region, OPS, PHMSA
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
MarkWest Ranger Pipeline Company, LLC, ) CPF No. 2-2012-5007
)
)
)
Respondent. )
____________________________________ )
CORRECTED FINAL ORDER
On March 28-29, 2012, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and
Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS),
conducted an on-site inspection of the Public Awareness Program of MarkWest Ranger Pipeline
Company, LLC (MarkWest or Respondent) in Ashland, Kentucky. MarkWest’s Public
Awareness Program covers MarkWest’s Appalachian Liquids Pipeline System (ALPS), which
comprises the 40.69-mile TranSandy Pipeline and the 36.03-mile Siloam Pipeline.
As a result of the inspection, the Director, Southern Region, OPS, issued to Respondent, by letter
dated June 19, 2012, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed
Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed
finding that MarkWest violated 49 C.F.R. § 195.440 and proposed assessing a civil penalty of
$17,600 for the alleged violation. The Notice also proposed ordering Respondent to take certain
measures to correct the alleged violation.
Respondent responded to the Notice by letter dated August 20, 2012 (Response). MarkWest
contested one of the allegations and requested a hearing. A hearing was subsequently held on
October 26, 2012 in the PHMSA Southern Region Office, Atlanta, Georgia, with an attorney
from the Office of Chief Counsel, PHMSA, presiding. At the hearing, Respondent was
represented by counsel. After the hearing, Respondent provided a post-hearing statement for the
record, by letter dated November 30, 2012 (Closing).
FINDING OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 195 as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.440, which states:



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§ 195.440 Public awareness.
(a) Each pipeline operator must develop and implement a written continuing public
education program that follows the guidance provided in the American Petroleum
Institute’s (API) Recommended Practice (RP) 1162 (incorporated by reference, see §
195.3).
(b) The operator's program must follow the general program recommendations of
API RP 1162 and assess the unique attributes and characteristics of the operator's pipeline
and facilities.
The Notice alleged that Respondent violated 49 C.F.R. § 195.440 by failing to assess the unique
characteristics and attributes of its pipeline facilities in its continuing public education program.
Specifically, the Notice alleged that MarkWest distributed baseline message or continuing public
education brochures to the affected public, excavators, emergency responders, and public
officials for calendar years 2009, 2010, and 2011 that did not identify the product transported as
a natural gas liquid (NGL) or as a highly volatile liquid (HVL). Furthermore, the Region
alleged that the brochures distributed in 2011 erroneously identified the product transported in
ALPS as natural gas rather than HVL. In the Notice and at the hearing, the Region stated that
MarkWest’s references to natural gas in its public education program materials violated
§ 195.440(b) because natural gas has different characteristics and attributes than HVL.
Furthermore, at the hearing, the Region argued that Respondent’s failure to properly describe
HVL characteristics and inclusion of incorrect information could endanger the public and
potentially cause incorrect response(s) to a pipeline release.
In its Response and at the hearing, MarkWest explained that it provided baseline messages (i.e.
public awareness information via brochures) in collaboration with other operators for the years
indicated above. MarkWest stated that the collaborative brochures did mention the presence of
HVLs and that, from a public information perspective, the characteristics of natural gas and HVL
are similar, so the references to natural gas were not misleading. MarkWest also argued that it
believed its collaborative approach was less confusing to landowners who may live near various
rights of way because the landowners or affected public might otherwise be inundated with
information from different operators.
With respect to MarkWest’s arguments about the benefits of its collaborative approach, the
Southern Region maintained that the intent of the regulation, rather than educating the public at
large about general pipeline safety, is to educate specific targeted audiences about pipelines that
may affect them. I agree that § 195.440(b) requires that operators provide specific information
about its facilities. On the other hand, API RP 1162 does encourage operators to, “convey
important information about the company, the industry, pipeline safety,” etc. to its target
audiences. See API RP 1162, 5.1.1. Therefore, the presence of information about different types
of pipelines does not, on its own, violate the regulation.
To determine whether violations occurred, it is necessary to examine the content of MarkWest’s
public education materials for each year listed, to evaluate whether: 1.) the material described
unique attributes of MarkWest’s ALPS pipeline, 2.) recipients of the brochure would be able to
distinguish between information relevant to ALPS and general pipeline information, and 3.)
information was accurate.



3
MarkWest’s 2009 brochure does not list NGLs or HVLs as the product transported in its
pipeline, nor does it include HVLs in its list of pipeline products included in the section entitled,
“Potential Hazards of Pipeline Products.” This list includes hazardous liquids, refined products,
crude oil, natural gas, oxygen, chemicals, etc. In the section entitled, “Recognizing a Pipeline
Leak,” the brochure lists the following various signs of a pipeline leak, “a pool of liquid on the
ground near a pipeline, a dense white cloud or fog over a pipeline, . . .an unusual dry spot in
otherwise moist field, . . .an unusual smell or gaseous odor . . ., frozen ground at the pipeline in
warm weather, . . .” The “white cloud” reference is an accurate description of an HVL release,
but a reader of the materials would not be able to distinguish that description from the others
listed as the one relevant to ALPS. Furthermore, the “white cloud” reference is the only
information specific reference to HVLs in the 2009 brochure.1 The brochure did not state that
HVLs are heavier than air and can settle in low lying areas, causing increased ignition hazard
and asphyxiation risk, nor did the brochure state that HVLs cause eye and nose irritation.
MarkWest’s 2010 public education brochure provides more information to the affected public of
the unique attributes and characteristics of its HVL facility but still exhibits problems. The
brochure does not specifically mention the ALPS or that the relevant pipeline transports HVLs. It
describes how to recognize leaks from different types of pipelines, including HVLs and other
products, such as natural gas and landfill gas. The brochure correctly describes a “vaporous fog”
as one sign of a pipeline leak. Furthermore, it states, “HVL vapors are heavier than air and can
collect in low areas such as ditches, sewers, etc.” Despite this useful information, the brochure
also states, “Highly Volatile Liquids (HVL’s) can be odorless and colorless in their natural state
and most are considered irritants to eyes and nose. Commercial odorants are added to many
HVL’s to assist in detection of a leak.” While the above statement may be true, the NGLs/HVLs
in the ALPS are not odorized, so the statement that “Commercial odorants are added to many
HVL’s to assist in the detection of a leak” could lead to the expectation by recipients of the
brochure that the ALPS is odorized.2 Therefore, in the absence of the distinctive “rotten
eggs”/mercaptan smell, members of the public might not detect a leak or might take longer to
detect/report a leak of the ALPS.
Finally, MarkWest’s 2011 public education materials contain further improvements from the
previous years but also a major flaw. The first page of the brochure contains only information
relevant to HVLs, including that HVLs are heavier than air. Unlike the prior years, the first page
does not include information specific to other pipeline products. The brochure also includes the
following accurate statement about odorization, “Natural Gas and Highly Volatile Liquids are
colorless, tasteless and odorless unless commercial odorants or Mercaptan is added.” However,
page 4 of the 2011 brochure includes a material safety data sheet (MSDS) for natural gas, which
is incorrect. The specific inclusion of the natural gas MSDS and no other MSDS would give the
impression that it is specific to the ALPS. The MSDS describes natural gas as “Lighter than air
and will generally rise and dissipate. May gather in a confined space and travel to a source of
1 I say “only ‘possible’ reference to HVLs” because neither HVLs nor NGLs are explicitly mentioned in the 2009
brochure.
2 MarkWest email correspondence, March 3, 2013.



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ignition.”3 This information is inaccurate and potentially dangerous, as HVLs are not lighter
than air, will not necessarily dissipate, and may gather in areas other than “a confined space.”
In its post-hearing submission (Closing), MarkWest argued that PHMSA’s allegation of violation
was based on a “subjective standard” that PHMSA interpreted inconsistently with its plain
meaning. According to MarkWest, the regulation does not require that the educational materials
name the product and only requires general pipeline safety information that includes some
information relevant to its facilities, even if the relevant information is presented alongside non-
relevant information. MarkWest also argued that its brochures complied with the “letter of the
law” because each included some information relevant to an HVL pipeline release. More
specifically, MarkWest pointed to mention in the 2009 brochure of “a dense white cloud or fog
over a pipeline,” and a “vaporous fog” in the 2010 brochure. It argued that this language,
applicable to an HVL release, described what a member of the public might witness were a
release to occur, and that this is the type of “unique attributes and characteristics” the regulation
is referring to. MarkWest acknowledged at the hearing that the inclusion of the natural gas
MSDS was “misleading and a mistake,” but it maintained that many of the attributes of natural
gas and NGLs are the same and that the MSDS inclusion, “did not detract from the information
presented in the brochure.”4
I am not persuaded by MarkWest’s position. Section 195.440(b) requires that operators include
information about the “unique attributes and characteristics of the operator's pipeline and
facilities” (emphasis added). This standard cannot be met by providing general pipeline safety
information alone or relevant information alongside non-relevant information as MarkWest did
in its 2009 and 2010 brochures. More specifically, the purpose of the 2009 brochure was plainly
to provide general pipeline safety information and was not specific to HVL pipelines; the
descriptions of various types of pipeline releases such as crude oil alongside description of an
HVL release would not convey to the resident that the reason it was receiving the materials was
the presence of an HVL pipeline. Also, the presentation of such different products/risks together
is likely to result in confusion or the reader forgetting much of the material due to “information
overload,” further diminishing the likelihood that the reader will come away with an
understanding of the “unique attributes and characteristics” of the pipeline that affects it.
Furthermore, although the 2010 brochure included more information about HVLs, it still
included information about natural gas, which has different attributes and characteristics. The
2010 brochure also exemplifies why providing materials that are not facility-specific is risky.
The statement in that brochure that many HVL facilities are odorized is relevant to HVLs and not
necessarily incorrect. However, given that the NGLs in the ALPS are not odorized, the statement
is misleading and potentially dangerous. Finally, the 2011 brochure violated the regulation due
to the inclusion of the incorrect MSDS that stated that natural gas is, “Lighter than air and will
generally rise and dissipate.”
3 MarkWest also provided PHMSA with a copy of a letter, dated 2011, for school administrators that included the
erroneous “Natural Gas” MSDS, including the incorrect statement regarding ALPS, “Lighter than air and will
generally rise and dissipate. May gather in a confined space and travel to a source of ignition.”
4 Response at 2.



5
Therefore, the presence of general pipeline information alongside information relevant to the
operator’s facilities can serve to confuse or diffuse the relevant information about the unique
attributes and characteristics of the operator’s facilities. In that case, the reader comes away with
no specific information about the pipeline that could affect him/her, and he/she may even
become confused about what to look/hear/smell for in identifying a leak. On the other hand, if
MarkWest had specified that the ALPS carried NGLs, it could have then provided information
about the characteristics of NGLs and supplemental information about other pipelines if it
desired to educate about general pipeline safety.
Accordingly, after considering all of the evidence and legal issues presented, I find MarkWest
violated 49 C.F.R. § 195.440(b) because its public education materials failed to properly assess
the unique attributes and characteristics of its pipeline and facilities when the materials contained
either only general pipeline information (i.e. relevant information comingled with non-relevant
information) or inaccurate information about the ALPS pipeline.
ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any
related series of violations.5 In determining the amount of a civil penalty under 49 U.S.C.
§ 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect
that the penalty may have on its ability to continue doing business; and the good faith of
Respondent in attempting to comply with the pipeline safety regulations. In addition, I may
consider the economic benefit gained from the violation without any reduction because of
subsequent damages, and such other matters as justice may require. The Notice proposed a total
civil penalty of $17,600 for the violations cited above.
Item 1: The Notice proposed a civil penalty of $17,600 for Respondent’s violation of 49 C.F.R.
§ 195.440(b), for failing to assess the unique characteristics and attributes of its pipeline facilities
in its continuing public education program.
In its Closing, MarkWest argued that its efforts to comply with the regulation were “in good
faith.” PHMSA agrees that MarkWest acted in good faith and calculated the proposed civil
penalty accordingly. MarkWest did not specifically challenge the civil penalty or request a
reduction, as it focused its arguments on whether a violation occurred. However, I will briefly
evaluate PHMSA’s considerations in determining the proposed civil penalty. With respect to the
“nature” of these violations, PHMSA considered the fact that this was mainly a records violation,
rather than a maintenance or equipment violation. Next, for the “circumstances,” PHMSA
considered that this violation occurred three years in a row. With respect to “gravity,” PHMSA
considered that although it was a recurring violation, the threat to safety or the environment was
minimal. As for “culpability,” PHMSA noted that MarkWest did make good faith attempts to
5 The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, Pub. L. No. 112-90, § 2(a)(1), 125 Stat.
1904, January 3, 2012, increased the civil penalty liability for violating a pipeline safety standard to $200,000 per
violation for each day of the violation, up to a maximum of $2,000,000 for any related series of violations.



6
comply with the regulation, despite the violation.
After review of the record and the assessment criteria, I find that the civil penalty proposed in the
Notice is reasonable.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent a total civil penalty of $17,600 for violation of 49 C.F.R. § 195.440(b).
Payment of the civil penalty must be made within 20 days of service of this Final Order.
Payment may be made by sending a certified check or money order (containing the CPF Number
for this case), made payable to “U.S. Department of Transportation,” to the Federal Aviation
Administration, Mike Monroney Aeronautical Center, Financial Operations Division (AMZ-
341), P.O. Box 269039, Oklahoma City, Oklahoma 73125. Federal regulations (49 C.F.R.
§ 89.21(b)(3)) also permit payment to be made by wire transfer through the Federal Reserve
Communications System (Fedwire), to the account of the U.S. Treasury. Detailed instructions
are contained in the enclosure. Questions concerning wire transfers should be directed to:
Financial Operations Division (AMZ-341), Federal Aviation Administration, Mike Monroney
Aeronautical Center, P.O. Box 269039, Oklahoma City, Oklahoma 73125. The Financial
Operations Division telephone number is (405) 954-8893.
Failure to pay the $17,600 civil penalty will result in accrual of interest at the current annual rate
in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 1 in the Notice for violation of 49
C.F.R. §§ 195.440. Under 49 U.S.C. § 60118(a), each person who engages in the transportation
of hazardous liquids or who owns or operates a pipeline facility is required to comply with the
applicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C.
§ 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to
ensure compliance with the pipeline safety regulations applicable to its operations:
1. With respect to the violation of § 195.440 (Item 1), Respondent must develop and
distribute new baseline message material to affected municipalities, school districts,
businesses, and residents near pipeline facility locations that adequately addresses the
unique attributes and characteristics of the NGLs transported in the ALPS.
2. Provide written documentation to Director, Southern Region, within 90 days
following your receipt of the Final Order, that Compliance Order Item 1 has been
completed.
3. It is requested that MarkWest maintain documentation of the safety improvement



7
costs associated with fulfilling this Compliance Order and submit the total to the
Director, Southern Region. It is requested that these costs be reported in two
categories: (1) total cost associated with preparation/revision of plans, procedures,
studies and analyses; and (2) total cost associated with replacements, additions, and
other changes to pipeline infrastructure.
The Director may grant an extension of time to comply with the required items upon a written
request timely submitted by the Respondent and demonstrating good cause for an extension.
WARNING ITEMS
With respect to Items 2 and 3, the Notice alleged probable violations of Part 195.440 but did not
propose a civil penalty or compliance order for these items. Therefore, these are considered to
be warning items. The warning(s) were for:
49 C.F.R. § 195.440(i) (Item 2) ─ Respondent’s alleged failure to have program
documentation, evaluation results, or other records to demonstrate that it had
conducted a substantive review of Respondent’s Public Awareness Program, as
required by API RP 1162 and § 195.400; and
49 C.F.R. § 195.440(a) (Item 3) ─ Respondent’s alleged failure to properly
develop and implement a written continuing public education program that
follows API RP 1162.
MarkWest did not contest these allegations. If OPS finds a violation of any of these items in a
subsequent inspection, Respondent may be subject to future enforcement action.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $200,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.
Under 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline
Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC
20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA
will accept petitions received no later than 20 days after receipt of service of this Final Order by
the Respondent, provided they contain a brief statement of the issue(s) and meet all other
requirements of 49 C.F.R. § 190.215. The filing of a petition automatically stays the payment of
any civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all
other terms and conditions of this Final Order are effective upon service in accordance with 49
C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

220125007_closure letter_07232013_.pdf

of Transportation
U.S. Department
233 Peachtree Street Ste. 600
Atlanta, GA 30303
Pipeline and
Administration
Hazardous Materials Safety
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
July 23, 2013
Mr. John Mollenkopf
Senior Vice President, Chief Operations Officer
Mark West Ranger Pipeline Company
1515 Arapahoe Street, Tower 2, Suite 700
Denver, CO 80202-2126
CPF 2-2012-5007
Dear Mr. Mollenkopf:
On April 18, 2013, the Pipeline and Hazardous Materials Safety Administration (PHMSA),
Office of Pipeline Safety (OPS) issued to Mark West Ranger Pipeline Company (MarkWest) a
Final Order in the above-referenced case. The Final Order included an assessed civil penalty
and a Compliance Order (CO).
On July 22, 2013, the OPS Southern Region received Mark West's written response to the
Compliance Order. Based on our review of this response and our confirmation that
Mark West has paid the civil penalty, we have determined that Mark West has complied with
the terms of the Final Order. This case is now closed and no further action is necessary with
respect to the matters involved in this case.
Please be advised that this letter refers only to the above referenced order (CPF 2-2012-5007)
and not to any other OPS cases, if any.
Thank you for your cooperation in this matter.
Sincerely,
-
Director, Office of Pipeline Safety
PHMSA Southern Region
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