{"operation":"document","citation":"CPF 220165003H","title":"MARATHON PIPE LINE LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-04-22","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-220165003h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-220165003h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-220165003h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/220165003H","body":"Corrective Action Order involving MARATHON PIPE LINE LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2016-04-22 and is reported as closed as of 2017-11-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n220165003H_Amended Corrective Action Order_05182016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165003H/220165003H_Amended%20Corrective%20Action%20Order_05182016.pdf\n\n220165003H_Amended Corrective Action Order_05182016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165003H/220165003H_Amended%20Corrective%20Action%20Order_05182016_text.pdf\n\n220165003H_Closure Letter_11072017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165003H/220165003H_Closure%20Letter_11072017.pdf\n\n220165003H_Closure Letter_11072017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165003H/220165003H_Closure%20Letter_11072017_text.pdf\n\n220165003H_Corrective Action Order_04222016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165003H/220165003H_Corrective%20Action%20Order_04222016.pdf\n\n220165003H_Corrective Action Order_04222016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165003H/220165003H_Corrective%20Action%20Order_04222016_text.pdf\n\n220165003H_Corrective Action Order_04222016_text.pdf\n\nApril 22, 2016\nVIA CERTIFIED MAIL AND FAX TO: (419) 421-3125\nMr. Craig Pierson\nPresident\nMarathon Pipe Line, LLC\n539 South Main Street\nFindlay, Ohio 45840\nRe: CPF No. 2-2016 5003H\nDear Mr. Pierson:\nEnclosed is a Corrective Action Order issued in the above-referenced case. It requires Marathon\nPipe Line, LLC, to take certain corrective actions with respect to the Robinson-Mt. Vernon 10-\ninch Products Pipeline that failed on April 17, 2016, in Wabash County, Illinois. Service is\nbeing made by certified mail and facsimile. Service of the Corrective Action Order by electronic\ntransmission is deemed complete upon transmission and acknowledgement of receipt, or as\notherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this Order are\neffective upon completion of service.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of\nPipeline Safety, PHMSA\nMr. James Urisko, Regional Director, Southern Region, Office of Pipeline Safety, PHMSA\n\n\n\nU. S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n)\nIn the Matter of )\n)\nMarathon Pipe Line, LLC, ) CPF No. 2-2016-5003H\n)\nRespondent. )\n)\nCORRECTIVE ACTION ORDER\nA. Purpose and Background:\nThis Corrective Action Order (Order) is being issued under the authority of 49 U.S.C. § 60112 to\nrequire Marathon Pipe Line, LLC (Marathon or Respondent), to take the necessary corrective\naction to protect the public, property, and the environment from potential hazards associated with\nthe recent failure on its Robinson-Mt. Vernon 10-inch products pipeline Marathon has\nownership interest in approximately 2,900 miles of pipeline across nine states and associated\ncrude oil and product storage assets in the Midwest and Gulf Coast regions.1 Marathon operates\na 78.4-mile pipeline segment referred to as the Robinson-Mt. Vernon 10-inch products pipeline\n(Mt. Vernon Line). The Mt. Vernon Line passes through Crawford, Lawrence, and Wabash\nCounties in Illinois and through Gibson and Posey Counties in Indiana. The failure, which was\nfirst reported by Marathon on April 17, 2016, occurred at the Mt. Vernon Line crossing over the\nWabash River in Wabash County, Illinois (Wabash River Crossing), located between the\nRobinson Refinery in Robinson, Illinois, and the Mt. Vernon Station in Mt. Vernon, Indiana.\nAs of the date of this Order, Marathon estimates a release of 48,300 gallons of ultra-low sulfur\ndiesel fuel from the Mt. Vernon Line failure (the Failure). The cause of the Failure has not yet\nbeen determined.\nPursuant to 49 U.S.C. § 60117, the Office of Pipeline Safety (OPS), PHMSA, initiated an\ninvestigation of the Failure, the preliminary findings of which are as follows.\nPreliminary Findings:\n1) On the morning of April 17, 2016, a resident on the Illinois side of the Wabash River\nobserved a sheen on the river water, downstream of the Wabash River Crossing. The\n1 http://www.marathonpipeline.com/Who_We_Are/Investor_Information/ (last accessed on\nApril 21, 2016)\n\n\n\nCPF No. 2-2016 5003H\n3\n2) 3) 4) 5) 6) 7) 8) 9) resident notified the Wabash County, Illinois Sheriff’s Department, which in turn,\nnotified the Mt. Carmel, Illinois, Fire Department at 11:25 a.m., Central Daylight\nTime (CDT).\nThe Mt. Carmel Fire Department observed the sheen on the river and, after\nreviewing its pipeline maps, notified Marathon at 11:59 a.m.\nUpon notification, Respondent deployed crews to investigate the reported sheen.\nMarathon confirmed the presence of a sheen on the Wabash River and consequently\nshut down the Mt. Vernon Line by closing block valve TWRKIRK-MVERBVTR-\n22, (TR-22), located in Illinois at milepost (MP) 51.0, at 2:20 p.m. CDT and also\nclosing block valve TWRILIN-MVERBVTR-23, (TR 23), located Indiana at MP\n55.5, at 2:31 p.m. CDT. The segment between these two block valves spans – a\ndistance of 4.5 miles (Isolated Segment).\nAt 2:54 p.m. CDT on April 17, 2016, Respondent initially reported a sheen on the\nWabash River to the National Response Center (NRC Report No. 1145495). This\nNRC report was updated the same day at 11:06 p.m. CDT, reporting the release of\ndiesel from its pipeline (NRC Report No. 1145511).\nRespondent estimates 48,300 gallons of ultra-low sulfur diesel fuel have been\nreleased as a result of the Failure. Marathon also reports that sheen was discovered\nat the confluence of the Wabash and Ohio Rivers. Marathon has deployed five\nShoreline Cleanup and Assessment Technique (SCAT) teams, whose cleanup\noperations are on-going.\nOn April 17, 2016, Respondent’s personnel also attempted boom deployment but\nwere hampered by high water levels and high river velocity. Marathon also\ndispatched an aerial patrol to determine the extent of the sheen, and began setting up\nits unified incident command center in Grayville, IL.\nThe Mt. Vernon Line is a single 10-inch diameter products pipeline that transports\nrefined products, a blend of grade gasoline, ultra-low sulfur diesel, and jet fuel, in a\nbatched system. The pipeline originates at the Robinson Refinery in Robinson,\nIllinois, and terminates at the Mt. Vernon station in Mt. Vernon, Indiana, a distance\nof approximately 78.4 miles (Affected Segment).\nThe Failure occurred on the Affected Segment on the Mt. Vernon Line, at the\nWabash River Crossing near milepost (MP) 53.2 (Failure Site).\nThe Affected Segment was constructed in 1952 and consists of 10-inch diameter,\n0.307” wall thickness, Grade API 5L X42 Low-Frequency Electric Resistance\nWelded (LF-ERW) seam pipe. The Affected Segment also has a coal tar coating and\nan impressed current cathodic protection (CP) system. The manufacturer of the\npipeline is unknown.\n\n\n\nCPF No. 2-2016 5003H\n4\n10) The maximum operating pressure (MOP) of Respondent’s Mt. Vernon Line is 1,369\npounds per square inch (psig), as established by an 11-hour hydrostatic test in\nAugust 2005. At the time of the Failure, the Mt. Vernon Line was operational but no\nproduct was flowing through the pipeline.\n11) Marathon asserts that cessation of operation of the Mt. Vernon Line occurred for\nreasons unrelated to the Failure.\n12) On April 17, 2016, at a site close to the Wabash River Crossing where the sheen had\nbeen observed, Respondent took water samples to confirm concentration of\npetroleum product in the water, and deployed divers to assess the condition of the\nMt. Vernon Line.\n13) Respondent’s divers found that approximately 60 feet of the Mt. Vernon Line was\nexposed and no longer covered by the river bottom. Additionally, portions of the 60-\nfoot segment of exposed pipeline were not supported by the river bottom.\n14) Respondent injected the Mt. Vernon Line with water to determine if the line would\nhold pressure. The water-injection test revealed that the pipeline was not holding\npressure.\n15) Further, during this water-injection test, Respondent’s employees and PHMSA OPS\npersonnel observed bubbles in the water over the pipeline, as well as an increase in\ndiesel smell. Respondent’s employees and PHMSA OPS personnel believed the\nbubbles and smell collectively indicated a leak in the Mt. Vernon Line.\n16) Marathon reported to PHMSA that it believes the leak started on the Mt Vernon line\naround 3:00 a.m. CDT on April 16, 2016, at a small leak rate – the pressure on the\nMt. Vernon Line was 191 psig.\n17) Respondent notes the leak on the Mt. Vernon Line worsened over time because at\napproximately 5:00 a.m. CDT on April 16, 2016, the pressure calculated at 73 psig.\n18) Marathon has partnered with the U.S. Environmental Protection Agency, Illinois\nEnvironmental Protection Agency, the Illinois Emergency Management Agency, the\nIndiana Department of Environmental Management, the U.S. Coast Guard, and\nPHMSA to establish a Unified Command in order to more effectively respond to the\nFailure.\n19) There were no impacts to life or property as a result of the Failure.\n20) The cause of the Failure is unknown, and therefore it is also unknown if the\nconditions that led to the Failure on the Isolated Segment are also present on the\nAffected Segment. While the investigation is ongoing, the Mt. Vernon Line remains\nout of service.\n\n\n\nCPF No. 2-2016 5003H\n5\n21) Marathon has not yet developed a repair plan for the Isolated Segment, but is\nconsidering horizontally directionally drilling a new pipe section at the Wabash\nRiver Crossing as an alternative to repairing the failed line.\n22) Respondent also operates a 6-inch line that runs from Kirkwood Station, Illinois, to\nMt. Vernon Terminal, Indiana, a distance of approximately 57.3 miles. This line\nruns parallel to the Mt. Vernon Line and also crosses the Wabash River at MP 53.2.\nThis line was abandoned in 1984 and Respondent asserts it was not a factor in the\nFailure.\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility is or would be hazardous, requiring corrective action, is set\nforth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.\nSection 60112 and the regulations promulgated thereunder provide for the issuance of a\nCorrective Action Order, without prior notice and opportunity for hearing, upon a finding that\nfailure to issue the Order expeditiously would result in the likelihood of serious harm to life,\nproperty, or the environment. In such cases, an opportunity for a hearing and expedited review\nwill be provided as soon as practicable after the issuance of this Order.\nAfter evaluating the foregoing preliminary findings of fact, I find that continued operation of the\nAffected Segment without corrective measures is or would be hazardous to life, property, or the\nenvironment. Additionally, the Mt. Vernon Line was constructed in 1952 of low frequency\nERW pipe, a known threat to pipeline integrity under certain conditions, and is used to transport\nproducts of a hazardous nature. Further, there is soil and water contamination in the vicinity and\ndownstream of the Failure Site, the cause of the Failure is still unknown, and therefore it also\nunknown if the conditions that led to the Failure on the Isolated Segment are present on the\nAffected Segment. Last, there is still an ongoing investigation to determine the cause of the\nFailure. Based on these factors, I find that a failure to issue this Order expeditiously to require\nimmediate corrective action would result in the likelihood of serious harm to life, property, or the\nenvironment.\nAccordingly, this Order mandating immediate corrective action is issued without prior notice and\nopportunity for a hearing. The terms and conditions of this Order are effective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may contest its issuance obtain expedited\nreview either by answering in writing or requesting a hearing under 49 C.F.R. § 190.211, to be\nheld as soon as practicable under the terms of such regulation, by notifying the Associate\nAdministrator for Pipeline Safety in writing, with a copy to the Director, Southern, PHMSA\n(Director). If Respondent requests a hearing, it will be held telephonically or in-person in\nSouthern Region office or Washington, D.C.\n\n\n\nCPF No. 2-2016 5003H\n6\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. In that event, PHMSA will notify\nRespondent of any additional measures that are required and an amended Order issued, if\nnecessary. To the extent consistent with safety, Respondent will be afforded notice and an\nopportunity for a hearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions:\nPursuant to 49 U.S.C. § 60112, I hereby order Marathon to immediately take the following\ncorrective actions for the Affected Segment and Isolated Segment:\nDefinitions:\nThe term “Affected Segment” means Respondent’s Robinson-Mt. Vernon 10-inch products\npipeline, (Mt. Vernon Line), originating at the Robinson Refinery in Robinson, Illinois and\nterminating at the Mt. Vernon station in Mt. Vernon, Indiana, a distance spanning approximately\n78.4 miles.\nThe term “Isolated Segment” means the section on Respondent’s Mt. Vernon line between block\nvalve TWRKIRK-MVERBVTR-22, (TR-22), located in Illinois at milepost (MP) 51.0, and\nblock valve TWRILIN-MVERBVTR-23, (TR 23), located Indiana at MP 55.5, at 2:31 p.m.\nC.D.T. The segment between these two block valves spans – a distance of 4.5 miles.\nThe term “Director” means Director, Southern Region, PHMSA.\nThe term “Failure Site” means the affected Segment on Respondent’s Mt. Vernon line, at the\nWabash River crossing near milepost (MP) 53.2\n1. Shutdown of Pipeline. Marathon must not operate the Isolated Segment until authorized to\ndo so by the Director.\nRestart Plan. Prior to resuming operation of the Isolated Segment, Marathon must develop\nand submit a written Restart Plan to the Director for prior approval.\na. The Director may approve the Restart Plan incrementally without approving the entire\nplan, but the Isolated Segment cannot resume operation until the Restart Plan is approved\nin its entirety.\nOnce approved by the Director, the Restart Plan will be incorporated by reference into\nthis Order.\nThe Restart Plan must include procedures to safely return the Isolated Segment to service\nand provide evidence that all mandated actions required prior to restart are adequately\ncompleted.\n2. b. c.\n\n\n\n3. CPF No. 2-2016 5003H\n7\nd. The Restart Plan must include repair or replacement of the Isolated Segment as follows:\ni. If the Isolated Segment is repaired, the pipeline repair must provide adequate support\nand protection to prevent future scour and damage.\nii. If the Isolated Segment is replaced, a horizontally directionally drilled (HDD)\npipeline crossing must be made.\ne. The Restart Plan must specify a day-light restart and must include advance\ncommunications with local emergency response officials.\nf. The Restart Plan must provide for a review of the Isolated Segment for conditions similar\nto those in which the failure occurred. This review should include a review of\nMarathon’s construction, operating and maintenance (O&M) and integrity management\nrecords such as ILI results, hydrostatic tests, root cause failure analysis of prior failures,\naerial and ground patrols, corrosion, cathodic protection, excavations and pipe\nreplacements. Marathon must address any findings that require remedial measures to be\nimplemented prior to restart.\ng. The Restart Plan must include documentation of the completion of all mandated actions\nand a management of change plan to ensure that all procedural modifications are\nincorporated into Marathon’s operations and maintenance manual.\nh. The Restart Plan must provide for hydrostatic pressure testing of the Isolated Segment.\ni. Prior to restart, Marathon must submit to the Director a contingency plan to operate and\nmonitor the Isolated Segment during flooding conditions, including enhanced patrolling\nand surveillance.\nj. Within 90 days of restarting the Isolated Segment, perform an ILI to ensure that there has\nbeen no metal loss, deformation or other damage to pipeline.\nMechanical and Metallurgical Testing. Within 45 days of receipt of this Order, Marathon\nmust complete mechanical and metallurgical testing, as well as a failure analysis of the failed\npipe, including an analysis of soil samples and any foreign materials. The testing and failure\nanalysis must be completed by an independent laboratory or expert. Complete the testing\nand analysis as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe section\nand other evidence from the Failure Site;\nb. Within 10 days of removing the failed pipe, develop and submit the testing protocol and\nthe proposed testing laboratory to the Director for prior approval;\nc. Prior to beginning the mechanical and metallurgical testing, provide the Director with the\nscheduled date, time, and location of the testing to allow for an OPS representative to\nwitness the testing;\n\n\n\nCPF No. 2-2016 5003H\n8\nd. Ensure the testing laboratory distributes all reports whether draft or final in their entirety\nto the Director at the same time they are made available to Marathon; and\ne. The Director may grant an extension of time, in accordance with Item 11 Extensions of\nTime, to complete the Mechanical and Metallurgical Testing.\n4. Root Cause Failure Analysis.\n5. 6. a. Within 90 days following receipt of this Order, Marathon must complete a root cause\nfailure analysis (RCFA) and submit a final report of this RCFA to the Director. The\nRCFA must be supplemented/facilitated by an independent third-party acceptable to the\nDirector and must document the decision making process and all factors contributing to\nthe failure, including river scouring of the pipeline crossing. The final report must include\nfindings and any lessons learned whether the findings and any lessons learned are\napplicable to other locations within Marathon’s pipeline system, and actions Marathon is\ntaking for those other locations where the lessons learned are applicable.\nb. The Director may grant an extension of time, in accordance with Item 11 Extensions of\nTime, to complete the RCFA. If an extension of time is granted, Marathon must\ncomplete a preliminary RCFA of the cause of the river bottom scouring and exposure of\nthe pipeline within 90 days of receipt of this Order and submit a report of this preliminary\nRCFA to the Director. The preliminary RCFA must be supplemented/facilitated by an\nindependent third-party acceptable to the Director and must document the decision\nmaking process and all factors contributing to the river scouring of the pipeline crossing.\nThe preliminary report must include findings and any lessons learned whether the\nfindings and any lessons learned are applicable to other locations within Marathon’s\npipeline system, and actions Marathon is taking for those other locations where the\nlessons learned are applicable.\nLeak Detection Plan. Within 90 days of receipt of this Order, perform a review and submit\nto the Director a written plan to improve the leak detection capability on the Affected\nSegment, to include conditions of non-flowing pipelines. The review must include a\ncomprehensive analysis of any SCADA, leak detection, surveillance, and other monitoring\nsystems on the Affected Segment. The written plan must include a schedule for improving\nthe leak detection capability on the Affected Segment through additional instrumentation,\nupdated hardware or software, installation/improvement of a computational pipeline\nmonitoring system and associated software programming, additional surveillance, pipeline\ncontrol staffing, ongoing leak surveys, and any other appropriate measures.\nEmergency Response Plan and Training Review. Marathon must review and assess the\neffectiveness of its emergency response plan with regards to the Failure. Include in the\nreview and assessment the on-scene response and support, coordination, and communication\nwith emergency responders and public officials. Also, include a review and assessment of the\neffectiveness of its emergency training program. Marathon must amend its emergency\nresponse plan and emergency training, if necessary, to reflect the results of this review. The\ndocumentation of this Emergency Response Plan and Training Review must be available for\ninspection by OPS or provided to the Director, if requested.\n\n\n\nCPF No. 2-2016 5003H\n9\n7. a. b. c. CAO Documentation Report (CDR). Marathon must create and revise, as necessary, a CAO\nDocumentation Report (CDR). When Marathon has concluded all the items in this Order, it\nwill submit the final CDR in its entirety to the Director. This will allow the Director to\ncomplete a thorough review of all actions taken by Marathon with regards to this Order prior\nto approving the closure of this Order. The intent is for the CDR to summarize all activities\nand documentation associated with this Order in one document.\nThe Director may approve the CDR incrementally without approving the entire CDR.\nOnce approved by the Director, the CDR will be incorporated by reference into this\nOrder.\nThe CDR must include but not be limited to:\ni. Table of Contents;\nii. Summary of the pipeline failure of April 17, 2016, and the response activities;\niii. Summary of pipe data/properties and all prior assessments of the Affected Segment;\niv. Summary of all tests, inspections, assessments, evaluations, and analysis required by\nthe Order;\nSummary of the Mechanical and Metallurgical Testing as required by the Order;\nSummary of the RCFA with all root causes as required by the Order;\nLessons learned while completing this Order;\nA path forward describing specific actions Marathon will take on its entire pipeline\nsystem as a result of the lessons learned from work on this Order; and\nix. Appendices (if required).\nOther Requirements:\nReporting. Marathon must submit quarterly reports to the Director that: (1) include all\navailable data and results of the testing and evaluations required by this Order; and (2)\ndescribe the progress of the repairs or other remedial actions being undertaken. The first\nquarterly report is due on August 1, 2016. The Director may change the interval for the\nsubmission of these reports.\nDocumentation of the Costs. It is requested but not required that Respondent maintain\ndocumentation of the costs associated with implementation of this Order. Include in each\nmonthly report submitted, the to-date total costs associated with: (1) preparation and revision\nof procedures, studies and analyses; (2) physical changes to pipeline infrastructure, including\nrepairs, replacements and other modifications; and (3) environmental remediation, if\napplicable.\nv. vi. vii. viii. 8. 9.\n\n\n\nCPF No. 2-2016 5003H\n10\n10. Approvals. With respect to each submission that under this Order requires the approval of\nthe Director, the Director may: (a) approve, in whole or part, the submission; (b) approve the\nsubmission on specified conditions; (c) modify the submission to cure any deficiencies; (d)\ndisapprove in whole or in part, the submission, directing that Respondent modify the\nsubmission, or (e) any combination of the above. In the event of approval, approval upon\nconditions, or modification by the Director, Respondent shall proceed to take all action\nrequired by the submission as approved or modified by the Director. If the Director\ndisapproves all or any portion of the submission, Respondent must correct all deficiencies\nwithin the time specified by the Director, and resubmit it for approval.\n11. Extensions of Time. The Director may grant an extension of time for compliance with any\nof the terms of this Order upon a written request timely submitted demonstrating good cause\nfor an extension.\nThe actions required by this Order are in addition to and do not waive any requirements that\napply to Respondent’s pipeline system under 49 C.F.R. Part 195, under any other order issued to\nRespondent under authority of 49 U.S.C. § 60101, et seq., or under any other provision of\nFederal or State law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential 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\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. 552(b).\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.\n§ 60120.\nIn your correspondence on this matter, please refer to CPF No. 2-2016-5003H and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nThe terms and conditions of this Order are effective upon receipt.\n__________________________________ __________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n220165003H_Amended Corrective Action Order_05182016_text.pdf\n\nMay 18, 2016\nVIA CERTIFIED MAIL AND FAX TO: (419) 421-3125\nMr. Craig Pierson\nPresident\nMarathon Pipe Line, LLC\n539 South Main Street\nFindlay, Ohio 45840\nRe: CPF No. 2-2016-5003H\nDear Mr. Pierson:\nEnclosed is an Amended Corrective Action Order (Amended Order) issued in the above-\nreferenced case, which replaces and supersedes the original Corrective Action Order issued to\nMarathon Pipe Line, LLC, on April 22, 2016, and which related to the failure of Marathon’s\nRobinson-Mt. Vernon 10-inch Products Pipeline on April 17, 2016, in Wabash County, Illinois.\nThe Amended Order is being issued to correct certain errors and make other technical\nclarifications to the original Corrective Action Order. The Amended Order amends preliminary\nfindings 3, 4, 9, 10, 16, and 17, the definition of “Isolated Segment” as applied to the required\ncorrective actions, and corrective actions 2(d) and 2(j).\nService is being made by certified mail and facsimile. Service of the Amended Order by\nelectronic transmission is deemed complete upon transmission and acknowledgement of receipt,\nor as otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this Amended\nOrder are effective upon completion of service.\nThank you for your cooperation in this matter.\nSincerely,\nAlan K. Mayberry\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of\nPipeline Safety, PHMSA\nMr. James Urisko, Regional Director, Southern Region, Office of Pipeline Safety,\nPHMSA\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n)\nIn the Matter of )\n)\nMarathon Pipe Line, LLC, ) CPF No. 2-2016-5003H\n)\nRespondent. )\n)\nAMENDED CORRECTIVE ACTION ORDER\nPurpose and Background:\nThis Amended Corrective Action Order (Order) is being issued under the authority of 49 U.S.C.\n§ 60112 to require Marathon Pipe Line, LLC (Marathon or Respondent), to take the necessary\ncorrective action to protect the public, property, and the environment from potential hazards\nassociated with the recent failure on its Robinson-Mt. Vernon 10-inch products pipeline.\nMarathon operates a 78.4-mile pipeline segment referred to as the Robinson-Mt. Vernon 10-inch\nproducts pipeline (Mt. Vernon Line). The pipeline passes through Crawford, Lawrence, and\nWabash Counties in Illinois and through Gibson and Posey Counties in Indiana, transporting\nrefined products, a blend of grade gasoline, ultra-low sulfur diesel, and jet fuel, in a batched\nsystem. On April 17, 2016, a reportable accident occurred at the Mt. Vernon Line crossing over\nthe Wabash River in Wabash County, Illinois (Wabash River Crossing), located between the\nRobinson Refinery in Robinson, Illinois, and the Mt. Vernon Station in Mt. Vernon, Indiana.\nAs of April 22, 2016, Marathon estimated a release of 48,300 gallons of ultra-low sulfur diesel\nfuel from the Mt. Vernon Line failure (the Failure). The cause of the Failure has not yet been\ndetermined.\nOn April 22, 2016, PHMSA issued a Corrective Action Order to Marathon. This Amended\nCorrective Action Order replaces and supersedes the CAO issued to Marathon on April 22, 2016.\nPursuant to 49 U.S.C. § 60117, the Office of Pipeline Safety (OPS), PHMSA, initiated an\ninvestigation of the Failure, the preliminary findings of which are as follows.\nPreliminary Findings:\n1) On the morning of April 17, 2016, a resident on the Illinois side of the Wabash River\nobserved a sheen on the river water, downstream of the Wabash River Crossing. The\nresident notified the Wabash County, Illinois Sheriff’s Department, which in turn,\n\n\n\nnotified the Mt. Carmel, Illinois, Fire Department at 11:25 a.m., Central Daylight\nTime (CDT).\n2) The Mt. Carmel Fire Department observed the sheen on the river and, after\nreviewing its pipeline maps, notified Marathon at 11:59 a.m.\n3) Upon notification, Respondent deployed crews to investigate the reported sheen.\nMarathon confirmed the presence of a sheen on the Wabash River and consequently\nshut down the Mt. Vernon Line by closing block valve TWRKIRK-MVERBVTR-\n22, (TR-22), located in Illinois at milepost (MP) 51.5, at 2:26 p.m. CDT and also\nclosing block valve TWRILIN-MVERBVTR-23, (TR 23), located Indiana at MP\n56.1, at 2:31 p.m. CDT. The segment between these two block valves spans – a\ndistance of 4.5 miles (Isolated Segment).\n4) At 1:54 p.m. CDT on April 17, 2016, Respondent initially reported a sheen on the\nWabash River to the National Response Center (NRC Report No. 1145495). This\nNRC report was updated the same day at 10:05 p.m. CDT, reporting the release of\ndiesel from its pipeline (NRC Report No. 1145511).\n5) Respondent estimates 48,300 gallons of ultra-low sulfur diesel fuel have been\nreleased as a result of the Failure. Marathon also reported that sheen was discovered\nat the confluence of the Wabash and Ohio Rivers. Marathon deployed five Shoreline\nCleanup and Assessment Technique (SCAT) teams.\n6) On April 17, 2016, Respondent’s personnel also attempted boom deployment but\nwere hampered by high water levels and high river velocity. Marathon also\ndispatched an aerial patrol to determine the extent of the sheen, and began setting up\nits unified incident command center in Grayville, IL.\n7) The Mt. Vernon Line is a single 10-inch diameter products pipeline that transports\nrefined products, a blend of grade gasoline, ultra-low sulfur diesel, and jet fuel, in a\nbatched system. The pipeline originates at the Robinson Refinery in Robinson,\nIllinois, and terminates at the Mt. Vernon station in Mt. Vernon, Indiana, a distance\nof approximately 78.4 miles (Affected Segment).\n8) The Failure occurred on the Affected Segment on the Mt. Vernon Line, at the\nWabash River Crossing near milepost (MP) 53.2 (Failure Site).\n9) The Affected Segment was constructed in 1951 and consists of 10-inch diameter,\n0.307” wall thickness, Grade API 5L X42 Low-Frequency Electric Resistance\nWelded (LF-ERW) seam pipe. The Affected Segment also has a coal tar coating and\nan impressed current cathodic protection (CP) system. The manufacturer of the\npipeline is unknown.\n10) The maximum operating pressure (MOP) of Respondent’s Mt. Vernon Line is 1,359\npounds per square inch (psig), as established by an 11-hour hydrostatic test in\n\n\n\nAugust 2015. At the time of the Failure, the Mt. Vernon Line was operational but no\nproduct was flowing through the pipeline.\n11) Marathon asserts that cessation of operation of the Mt. Vernon Line occurred for\nreasons unrelated to the Failure.\n12) On April 17, 2016, at a site close to the Wabash River Crossing where the sheen had\nbeen observed, Respondent took water samples to confirm concentration of\npetroleum product in the water, and deployed divers to assess the condition of the\nMt. Vernon Line.\n13) Respondent’s divers found that approximately 60 feet of the Mt. Vernon Line was\nexposed and no longer covered by the river bottom. Additionally, portions of the 60-\nfoot segment of exposed pipeline were not supported by the river bottom.\n14) Respondent injected the Mt. Vernon Line with water to determine if the line would\nhold pressure. The water-injection test revealed that the pipeline was not holding\npressure.\n15) Further, during this water-injection test, Respondent’s employees and PHMSA OPS\npersonnel observed bubbles in the water over the pipeline, as well as an increase in\ndiesel smell. Respondent’s employees and PHMSA OPS personnel believed the\nbubbles and smell collectively indicated a leak in the Mt. Vernon Line.\n16) Marathon reported to PHMSA that it believes the leak started on the Mt Vernon line\naround 3:00 a.m. CDT on April 17, 2016, at a small leak rate – the pressure on the\nMt. Vernon Line was 191 psig.\n17) Respondent notes the leak on the Mt. Vernon Line worsened over time because at\napproximately 5:00 a.m. CDT on April 17, 2016, the pressure calculated at 73 psig.\n18) Marathon partnered with the U.S. Environmental Protection Agency, Illinois\nEnvironmental Protection Agency, the Illinois Emergency Management Agency, the\nIndiana Department of Environmental Management, the U.S. Coast Guard, and\nPHMSA to establish a Unified Command in order to more effectively respond to the\nFailure.\n19) There were no impacts to life or property as a result of the Failure.\n20) The cause of the Failure is unknown, and therefore it is also unknown if the\nconditions that led to the Failure on the Isolated Segment are also present on the\nAffected Segment. While the investigation is ongoing, the Mt. Vernon Line remains\nout of service.\n21) Marathon has not yet developed a repair plan for the Isolated Segment, but is\nconsidering horizontally directionally drilling a new pipe section at the Wabash\nRiver Crossing as an alternative to repairing the failed line.\n\n\n\n22) Respondent also operates a 6-inch line that runs from Kirkwood Station, Illinois, to\nMt. Vernon Terminal, Indiana, a distance of approximately 57.3 miles. This line\nruns parallel to the Mt. Vernon Line and also crosses the Wabash River at MP 53.2.\nThis line was abandoned in 1984 and Respondent asserts it was not a factor in the\nFailure.\nDetermination of Necessity for Corrective Action Order and Right to Hearing:\nSection 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action\nOrder, after reasonable notice and the opportunity for a hearing, requiring corrective action,\nwhich may include the suspended or restricted use of a pipeline facility, physical inspection,\ntesting, repair, replacement, or other action, as appropriate. The basis for making the\ndetermination that a pipeline facility is or would be hazardous, requiring corrective action, is set\nforth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.\nSection 60112 and the regulations promulgated thereunder provide for the issuance of a\nCorrective Action Order, without prior notice and opportunity for hearing, upon a finding that\nfailure to issue the Order expeditiously would result in the likelihood of serious harm to life,\nproperty, or the environment. In such cases, an opportunity for a hearing and expedited review\nwill be provided as soon as practicable after the issuance of this Order.\nAfter evaluating the foregoing preliminary findings of fact, I find that continued operation of the\nAffected Segment without corrective measures is or would be hazardous to life, property, or the\nenvironment. Additionally, the Mt. Vernon Line was constructed in 1952 of low frequency\nERW pipe, a known threat to pipeline integrity under certain conditions, and is used to transport\nproducts of a hazardous nature. Further, there is soil and water contamination in the vicinity and\ndownstream of the Failure Site, the cause of the Failure is still unknown, and therefore it also\nunknown if the conditions that led to the Failure on the Isolated Segment are present on the\nAffected Segment. Last, there is still an ongoing investigation to determine the cause of the\nFailure. Based on these factors, I find that a failure to issue this Order expeditiously to require\nimmediate corrective action would result in the likelihood of serious harm to life, property, or the\nenvironment.\nAccordingly, this Order mandating immediate corrective action is issued without prior notice and\nopportunity for a hearing. The terms and conditions of this Order are effective upon receipt.\nWithin 10 days of receipt of this Order, Respondent may contest its issuance obtain expedited\nreview either by answering in writing or requesting a hearing under 49 C.F.R. § 190.211, to be\nheld as soon as practicable under the terms of such regulation, by notifying the Associate\nAdministrator for Pipeline Safety in writing, with a copy to the Director, Southern, PHMSA\n(Director). If Respondent requests a hearing, it will be held telephonically or in-person in\nSouthern Region office or Washington, D.C.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. In that event, PHMSA will notify\nRespondent of any additional measures that are required and an amended Order issued, if\n\n\n\nnecessary. To the extent consistent with safety, Respondent will be afforded notice and an\nopportunity for a hearing prior to the imposition of any additional corrective measures.\nRequired Corrective Actions:\nPursuant to 49 U.S.C. § 60112, I hereby order Marathon to immediately take the following\ncorrective actions for the Affected Segment and Isolated Segment:\nDefinitions:\nThe term “Affected Segment” means Respondent’s Robinson-Mt. Vernon 10-inch products\npipeline, (Mt. Vernon Line), originating at the Robinson Refinery in Robinson, Illinois and\nterminating at the Mt. Vernon station in Mt. Vernon, Indiana, a distance spanning approximately\n78.4 miles.\nThe term “Isolated Segment” means the section on Respondent’s Mt. Vernon line between block\nvalve TWRKIRK-MVERBVTR-22, (TR-22), located in Illinois at milepost (MP) 51.5, and\nblock valve TWRILIN-MVERBVTR-23, (TR 23), located Indiana at MP 56.1. The segment\nbetween these two block valves spans – a distance of 4.5 miles.\nThe term “Director” means Director, Southern Region, PHMSA.\nThe term “Failure Site” means the affected Segment on Respondent’s Mt. Vernon line, at the\nWabash River crossing near milepost (MP) 53.2\n1. Shutdown of Pipeline. Marathon must not operate the Isolated Segment until authorized to\ndo so by the Director.\n2. Restart Plan. Prior to resuming operation of the Isolated Segment, Marathon must develop\nand submit a written Restart Plan to the Director for prior approval.\na. The Director may approve the Restart Plan in","truncated":true,"body_characters":53120}