# MARATHON PIPE LINE LLC — Corrective Action Order

- **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:** Not available
- **summary:** CLOSED corrective action order.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-220165003h.md
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- **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.

Official case documents:

220165003H_Amended Corrective Action Order_05182016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165003H/220165003H_Amended%20Corrective%20Action%20Order_05182016.pdf

220165003H_Amended Corrective Action Order_05182016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165003H/220165003H_Amended%20Corrective%20Action%20Order_05182016_text.pdf

220165003H_Closure Letter_11072017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165003H/220165003H_Closure%20Letter_11072017.pdf

220165003H_Closure Letter_11072017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165003H/220165003H_Closure%20Letter_11072017_text.pdf

220165003H_Corrective Action Order_04222016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165003H/220165003H_Corrective%20Action%20Order_04222016.pdf

220165003H_Corrective Action Order_04222016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220165003H/220165003H_Corrective%20Action%20Order_04222016_text.pdf

220165003H_Corrective Action Order_04222016_text.pdf

April 22, 2016
VIA CERTIFIED MAIL AND FAX TO: (419) 421-3125
Mr. Craig Pierson
President
Marathon Pipe Line, LLC
539 South Main Street
Findlay, Ohio 45840
Re: CPF No. 2-2016 5003H
Dear Mr. Pierson:
Enclosed is a Corrective Action Order issued in the above-referenced case. It requires Marathon
Pipe Line, LLC, to take certain corrective actions with respect to the Robinson-Mt. Vernon 10-
inch Products Pipeline that failed on April 17, 2016, in Wabash County, Illinois. Service is
being made by certified mail and facsimile. Service of the Corrective Action Order by electronic
transmission is deemed complete upon transmission and acknowledgement of receipt, or as
otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this Order are
effective upon completion of service.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of
Pipeline Safety, PHMSA
Mr. James Urisko, Regional Director, Southern Region, Office of Pipeline Safety, PHMSA



U. S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
)
In the Matter of )
)
Marathon Pipe Line, LLC, ) CPF No. 2-2016-5003H
)
Respondent. )
)
CORRECTIVE ACTION ORDER
A. Purpose and Background:
This Corrective Action Order (Order) is being issued under the authority of 49 U.S.C. § 60112 to
require Marathon Pipe Line, LLC (Marathon or Respondent), to take the necessary corrective
action to protect the public, property, and the environment from potential hazards associated with
the recent failure on its Robinson-Mt. Vernon 10-inch products pipeline Marathon has
ownership interest in approximately 2,900 miles of pipeline across nine states and associated
crude oil and product storage assets in the Midwest and Gulf Coast regions.1 Marathon operates
a 78.4-mile pipeline segment referred to as the Robinson-Mt. Vernon 10-inch products pipeline
(Mt. Vernon Line). The Mt. Vernon Line passes through Crawford, Lawrence, and Wabash
Counties in Illinois and through Gibson and Posey Counties in Indiana. The failure, which was
first reported by Marathon on April 17, 2016, occurred at the Mt. Vernon Line crossing over the
Wabash River in Wabash County, Illinois (Wabash River Crossing), located between the
Robinson Refinery in Robinson, Illinois, and the Mt. Vernon Station in Mt. Vernon, Indiana.
As of the date of this Order, Marathon estimates a release of 48,300 gallons of ultra-low sulfur
diesel fuel from the Mt. Vernon Line failure (the Failure). The cause of the Failure has not yet
been determined.
Pursuant to 49 U.S.C. § 60117, the Office of Pipeline Safety (OPS), PHMSA, initiated an
investigation of the Failure, the preliminary findings of which are as follows.
Preliminary Findings:
1) On the morning of April 17, 2016, a resident on the Illinois side of the Wabash River
observed a sheen on the river water, downstream of the Wabash River Crossing. The
1 http://www.marathonpipeline.com/Who_We_Are/Investor_Information/ (last accessed on
April 21, 2016)



CPF No. 2-2016 5003H
3
2) 3) 4) 5) 6) 7) 8) 9) resident notified the Wabash County, Illinois Sheriff’s Department, which in turn,
notified the Mt. Carmel, Illinois, Fire Department at 11:25 a.m., Central Daylight
Time (CDT).
The Mt. Carmel Fire Department observed the sheen on the river and, after
reviewing its pipeline maps, notified Marathon at 11:59 a.m.
Upon notification, Respondent deployed crews to investigate the reported sheen.
Marathon confirmed the presence of a sheen on the Wabash River and consequently
shut down the Mt. Vernon Line by closing block valve TWRKIRK-MVERBVTR-
22, (TR-22), located in Illinois at milepost (MP) 51.0, at 2:20 p.m. CDT and also
closing block valve TWRILIN-MVERBVTR-23, (TR 23), located Indiana at MP
55.5, at 2:31 p.m. CDT. The segment between these two block valves spans – a
distance of 4.5 miles (Isolated Segment).
At 2:54 p.m. CDT on April 17, 2016, Respondent initially reported a sheen on the
Wabash River to the National Response Center (NRC Report No. 1145495). This
NRC report was updated the same day at 11:06 p.m. CDT, reporting the release of
diesel from its pipeline (NRC Report No. 1145511).
Respondent estimates 48,300 gallons of ultra-low sulfur diesel fuel have been
released as a result of the Failure. Marathon also reports that sheen was discovered
at the confluence of the Wabash and Ohio Rivers. Marathon has deployed five
Shoreline Cleanup and Assessment Technique (SCAT) teams, whose cleanup
operations are on-going.
On April 17, 2016, Respondent’s personnel also attempted boom deployment but
were hampered by high water levels and high river velocity. Marathon also
dispatched an aerial patrol to determine the extent of the sheen, and began setting up
its unified incident command center in Grayville, IL.
The Mt. Vernon Line is a single 10-inch diameter products pipeline that transports
refined products, a blend of grade gasoline, ultra-low sulfur diesel, and jet fuel, in a
batched system. The pipeline originates at the Robinson Refinery in Robinson,
Illinois, and terminates at the Mt. Vernon station in Mt. Vernon, Indiana, a distance
of approximately 78.4 miles (Affected Segment).
The Failure occurred on the Affected Segment on the Mt. Vernon Line, at the
Wabash River Crossing near milepost (MP) 53.2 (Failure Site).
The Affected Segment was constructed in 1952 and consists of 10-inch diameter,
0.307” wall thickness, Grade API 5L X42 Low-Frequency Electric Resistance
Welded (LF-ERW) seam pipe. The Affected Segment also has a coal tar coating and
an impressed current cathodic protection (CP) system. The manufacturer of the
pipeline is unknown.



CPF No. 2-2016 5003H
4
10) The maximum operating pressure (MOP) of Respondent’s Mt. Vernon Line is 1,369
pounds per square inch (psig), as established by an 11-hour hydrostatic test in
August 2005. At the time of the Failure, the Mt. Vernon Line was operational but no
product was flowing through the pipeline.
11) Marathon asserts that cessation of operation of the Mt. Vernon Line occurred for
reasons unrelated to the Failure.
12) On April 17, 2016, at a site close to the Wabash River Crossing where the sheen had
been observed, Respondent took water samples to confirm concentration of
petroleum product in the water, and deployed divers to assess the condition of the
Mt. Vernon Line.
13) Respondent’s divers found that approximately 60 feet of the Mt. Vernon Line was
exposed and no longer covered by the river bottom. Additionally, portions of the 60-
foot segment of exposed pipeline were not supported by the river bottom.
14) Respondent injected the Mt. Vernon Line with water to determine if the line would
hold pressure. The water-injection test revealed that the pipeline was not holding
pressure.
15) Further, during this water-injection test, Respondent’s employees and PHMSA OPS
personnel observed bubbles in the water over the pipeline, as well as an increase in
diesel smell. Respondent’s employees and PHMSA OPS personnel believed the
bubbles and smell collectively indicated a leak in the Mt. Vernon Line.
16) Marathon reported to PHMSA that it believes the leak started on the Mt Vernon line
around 3:00 a.m. CDT on April 16, 2016, at a small leak rate – the pressure on the
Mt. Vernon Line was 191 psig.
17) Respondent notes the leak on the Mt. Vernon Line worsened over time because at
approximately 5:00 a.m. CDT on April 16, 2016, the pressure calculated at 73 psig.
18) Marathon has partnered with the U.S. Environmental Protection Agency, Illinois
Environmental Protection Agency, the Illinois Emergency Management Agency, the
Indiana Department of Environmental Management, the U.S. Coast Guard, and
PHMSA to establish a Unified Command in order to more effectively respond to the
Failure.
19) There were no impacts to life or property as a result of the Failure.
20) The cause of the Failure is unknown, and therefore it is also unknown if the
conditions that led to the Failure on the Isolated Segment are also present on the
Affected Segment. While the investigation is ongoing, the Mt. Vernon Line remains
out of service.



CPF No. 2-2016 5003H
5
21) Marathon has not yet developed a repair plan for the Isolated Segment, but is
considering horizontally directionally drilling a new pipe section at the Wabash
River Crossing as an alternative to repairing the failed line.
22) Respondent also operates a 6-inch line that runs from Kirkwood Station, Illinois, to
Mt. Vernon Terminal, Indiana, a distance of approximately 57.3 miles. This line
runs parallel to the Mt. Vernon Line and also crosses the Wabash River at MP 53.2.
This line was abandoned in 1984 and Respondent asserts it was not a factor in the
Failure.
Determination of Necessity for Corrective Action Order and Right to Hearing:
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, after reasonable notice and the opportunity for a hearing, requiring corrective action,
which may include the suspended or restricted use of a pipeline facility, physical inspection,
testing, repair, replacement, or other action, as appropriate. The basis for making the
determination that a pipeline facility is or would be hazardous, requiring corrective action, is set
forth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.
Section 60112 and the regulations promulgated thereunder provide for the issuance of a
Corrective Action Order, without prior notice and opportunity for hearing, upon a finding that
failure to issue the Order expeditiously would result in the likelihood of serious harm to life,
property, or the environment. In such cases, an opportunity for a hearing and expedited review
will be provided as soon as practicable after the issuance of this Order.
After evaluating the foregoing preliminary findings of fact, I find that continued operation of the
Affected Segment without corrective measures is or would be hazardous to life, property, or the
environment. Additionally, the Mt. Vernon Line was constructed in 1952 of low frequency
ERW pipe, a known threat to pipeline integrity under certain conditions, and is used to transport
products of a hazardous nature. Further, there is soil and water contamination in the vicinity and
downstream of the Failure Site, the cause of the Failure is still unknown, and therefore it also
unknown if the conditions that led to the Failure on the Isolated Segment are present on the
Affected Segment. Last, there is still an ongoing investigation to determine the cause of the
Failure. Based on these factors, I find that a failure to issue this Order expeditiously to require
immediate corrective action would result in the likelihood of serious harm to life, property, or the
environment.
Accordingly, this Order mandating immediate corrective action is issued without prior notice and
opportunity for a hearing. The terms and conditions of this Order are effective upon receipt.
Within 10 days of receipt of this Order, Respondent may contest its issuance obtain expedited
review either by answering in writing or requesting a hearing under 49 C.F.R. § 190.211, to be
held as soon as practicable under the terms of such regulation, by notifying the Associate
Administrator for Pipeline Safety in writing, with a copy to the Director, Southern, PHMSA
(Director). If Respondent requests a hearing, it will be held telephonically or in-person in
Southern Region office or Washington, D.C.



CPF No. 2-2016 5003H
6
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. In that event, PHMSA will notify
Respondent of any additional measures that are required and an amended Order issued, if
necessary. To the extent consistent with safety, Respondent will be afforded notice and an
opportunity for a hearing prior to the imposition of any additional corrective measures.
Required Corrective Actions:
Pursuant to 49 U.S.C. § 60112, I hereby order Marathon to immediately take the following
corrective actions for the Affected Segment and Isolated Segment:
Definitions:
The term “Affected Segment” means Respondent’s Robinson-Mt. Vernon 10-inch products
pipeline, (Mt. Vernon Line), originating at the Robinson Refinery in Robinson, Illinois and
terminating at the Mt. Vernon station in Mt. Vernon, Indiana, a distance spanning approximately
78.4 miles.
The term “Isolated Segment” means the section on Respondent’s Mt. Vernon line between block
valve TWRKIRK-MVERBVTR-22, (TR-22), located in Illinois at milepost (MP) 51.0, and
block valve TWRILIN-MVERBVTR-23, (TR 23), located Indiana at MP 55.5, at 2:31 p.m.
C.D.T. The segment between these two block valves spans – a distance of 4.5 miles.
The term “Director” means Director, Southern Region, PHMSA.
The term “Failure Site” means the affected Segment on Respondent’s Mt. Vernon line, at the
Wabash River crossing near milepost (MP) 53.2
1. Shutdown of Pipeline. Marathon must not operate the Isolated Segment until authorized to
do so by the Director.
Restart Plan. Prior to resuming operation of the Isolated Segment, Marathon must develop
and submit a written Restart Plan to the Director for prior approval.
a. The Director may approve the Restart Plan incrementally without approving the entire
plan, but the Isolated Segment cannot resume operation until the Restart Plan is approved
in its entirety.
Once approved by the Director, the Restart Plan will be incorporated by reference into
this Order.
The Restart Plan must include procedures to safely return the Isolated Segment to service
and provide evidence that all mandated actions required prior to restart are adequately
completed.
2. b. c.



3. CPF No. 2-2016 5003H
7
d. The Restart Plan must include repair or replacement of the Isolated Segment as follows:
i. If the Isolated Segment is repaired, the pipeline repair must provide adequate support
and protection to prevent future scour and damage.
ii. If the Isolated Segment is replaced, a horizontally directionally drilled (HDD)
pipeline crossing must be made.
e. The Restart Plan must specify a day-light restart and must include advance
communications with local emergency response officials.
f. The Restart Plan must provide for a review of the Isolated Segment for conditions similar
to those in which the failure occurred. This review should include a review of
Marathon’s construction, operating and maintenance (O&M) and integrity management
records such as ILI results, hydrostatic tests, root cause failure analysis of prior failures,
aerial and ground patrols, corrosion, cathodic protection, excavations and pipe
replacements. Marathon must address any findings that require remedial measures to be
implemented prior to restart.
g. The Restart Plan must include documentation of the completion of all mandated actions
and a management of change plan to ensure that all procedural modifications are
incorporated into Marathon’s operations and maintenance manual.
h. The Restart Plan must provide for hydrostatic pressure testing of the Isolated Segment.
i. Prior to restart, Marathon must submit to the Director a contingency plan to operate and
monitor the Isolated Segment during flooding conditions, including enhanced patrolling
and surveillance.
j. Within 90 days of restarting the Isolated Segment, perform an ILI to ensure that there has
been no metal loss, deformation or other damage to pipeline.
Mechanical and Metallurgical Testing. Within 45 days of receipt of this Order, Marathon
must complete mechanical and metallurgical testing, as well as a failure analysis of the failed
pipe, including an analysis of soil samples and any foreign materials. The testing and failure
analysis must be completed by an independent laboratory or expert. Complete the testing
and analysis as follows:
a. Document the chain-of-custody when handling and transporting the failed pipe section
and other evidence from the Failure Site;
b. Within 10 days of removing the failed pipe, develop and submit the testing protocol and
the proposed testing laboratory to the Director for prior approval;
c. Prior to beginning the mechanical and metallurgical testing, provide the Director with the
scheduled date, time, and location of the testing to allow for an OPS representative to
witness the testing;



CPF No. 2-2016 5003H
8
d. Ensure the testing laboratory distributes all reports whether draft or final in their entirety
to the Director at the same time they are made available to Marathon; and
e. The Director may grant an extension of time, in accordance with Item 11 Extensions of
Time, to complete the Mechanical and Metallurgical Testing.
4. Root Cause Failure Analysis.
5. 6. a. Within 90 days following receipt of this Order, Marathon must complete a root cause
failure analysis (RCFA) and submit a final report of this RCFA to the Director. The
RCFA must be supplemented/facilitated by an independent third-party acceptable to the
Director and must document the decision making process and all factors contributing to
the failure, including river scouring of the pipeline crossing. The final report must include
findings and any lessons learned whether the findings and any lessons learned are
applicable to other locations within Marathon’s pipeline system, and actions Marathon is
taking for those other locations where the lessons learned are applicable.
b. The Director may grant an extension of time, in accordance with Item 11 Extensions of
Time, to complete the RCFA. If an extension of time is granted, Marathon must
complete a preliminary RCFA of the cause of the river bottom scouring and exposure of
the pipeline within 90 days of receipt of this Order and submit a report of this preliminary
RCFA to the Director. The preliminary RCFA must be supplemented/facilitated by an
independent third-party acceptable to the Director and must document the decision
making process and all factors contributing to the river scouring of the pipeline crossing.
The preliminary report must include findings and any lessons learned whether the
findings and any lessons learned are applicable to other locations within Marathon’s
pipeline system, and actions Marathon is taking for those other locations where the
lessons learned are applicable.
Leak Detection Plan. Within 90 days of receipt of this Order, perform a review and submit
to the Director a written plan to improve the leak detection capability on the Affected
Segment, to include conditions of non-flowing pipelines. The review must include a
comprehensive analysis of any SCADA, leak detection, surveillance, and other monitoring
systems on the Affected Segment. The written plan must include a schedule for improving
the leak detection capability on the Affected Segment through additional instrumentation,
updated hardware or software, installation/improvement of a computational pipeline
monitoring system and associated software programming, additional surveillance, pipeline
control staffing, ongoing leak surveys, and any other appropriate measures.
Emergency Response Plan and Training Review. Marathon must review and assess the
effectiveness of its emergency response plan with regards to the Failure. Include in the
review and assessment the on-scene response and support, coordination, and communication
with emergency responders and public officials. Also, include a review and assessment of the
effectiveness of its emergency training program. Marathon must amend its emergency
response plan and emergency training, if necessary, to reflect the results of this review. The
documentation of this Emergency Response Plan and Training Review must be available for
inspection by OPS or provided to the Director, if requested.



CPF No. 2-2016 5003H
9
7. a. b. c. CAO Documentation Report (CDR). Marathon must create and revise, as necessary, a CAO
Documentation Report (CDR). When Marathon has concluded all the items in this Order, it
will submit the final CDR in its entirety to the Director. This will allow the Director to
complete a thorough review of all actions taken by Marathon with regards to this Order prior
to approving the closure of this Order. The intent is for the CDR to summarize all activities
and documentation associated with this Order in one document.
The Director may approve the CDR incrementally without approving the entire CDR.
Once approved by the Director, the CDR will be incorporated by reference into this
Order.
The CDR must include but not be limited to:
i. Table of Contents;
ii. Summary of the pipeline failure of April 17, 2016, and the response activities;
iii. Summary of pipe data/properties and all prior assessments of the Affected Segment;
iv. Summary of all tests, inspections, assessments, evaluations, and analysis required by
the Order;
Summary of the Mechanical and Metallurgical Testing as required by the Order;
Summary of the RCFA with all root causes as required by the Order;
Lessons learned while completing this Order;
A path forward describing specific actions Marathon will take on its entire pipeline
system as a result of the lessons learned from work on this Order; and
ix. Appendices (if required).
Other Requirements:
Reporting. Marathon must submit quarterly reports to the Director that: (1) include all
available data and results of the testing and evaluations required by this Order; and (2)
describe the progress of the repairs or other remedial actions being undertaken. The first
quarterly report is due on August 1, 2016. The Director may change the interval for the
submission of these reports.
Documentation of the Costs. It is requested but not required that Respondent maintain
documentation of the costs associated with implementation of this Order. Include in each
monthly report submitted, the to-date total costs associated with: (1) preparation and revision
of procedures, studies and analyses; (2) physical changes to pipeline infrastructure, including
repairs, replacements and other modifications; and (3) environmental remediation, if
applicable.
v. vi. vii. viii. 8. 9.



CPF No. 2-2016 5003H
10
10. Approvals. With respect to each submission that under this Order requires the approval of
the Director, the Director may: (a) approve, in whole or part, the submission; (b) approve the
submission on specified conditions; (c) modify the submission to cure any deficiencies; (d)
disapprove in whole or in part, the submission, directing that Respondent modify the
submission, or (e) any combination of the above. In the event of approval, approval upon
conditions, or modification by the Director, Respondent shall proceed to take all action
required by the submission as approved or modified by the Director. If the Director
disapproves all or any portion of the submission, Respondent must correct all deficiencies
within the time specified by the Director, and resubmit it for approval.
11. Extensions of Time. The Director may grant an extension of time for compliance with any
of the terms of this Order upon a written request timely submitted demonstrating good cause
for an extension.
The actions required by this Order are in addition to and do not waive any requirements that
apply to Respondent’s pipeline system under 49 C.F.R. Part 195, under any other order issued to
Respondent under authority of 49 U.S.C. § 60101, et seq., or under any other provision of
Federal or State law.
Respondent may appeal any decision of the Director to the Associate Administrator for Pipeline
Safety. Decisions of the Associate Administrator shall be final.
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).
Failure to comply with this Order may result in the assessment of civil penalties and in referral to
the Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.
§ 60120.
In your correspondence on this matter, please refer to CPF No. 2-2016-5003H and for each
document you submit, please provide a copy in electronic format whenever possible.
The terms and conditions of this Order are effective upon receipt.
__________________________________ __________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

220165003H_Amended Corrective Action Order_05182016_text.pdf

May 18, 2016
VIA CERTIFIED MAIL AND FAX TO: (419) 421-3125
Mr. Craig Pierson
President
Marathon Pipe Line, LLC
539 South Main Street
Findlay, Ohio 45840
Re: CPF No. 2-2016-5003H
Dear Mr. Pierson:
Enclosed is an Amended Corrective Action Order (Amended Order) issued in the above-
referenced case, which replaces and supersedes the original Corrective Action Order issued to
Marathon Pipe Line, LLC, on April 22, 2016, and which related to the failure of Marathon’s
Robinson-Mt. Vernon 10-inch Products Pipeline on April 17, 2016, in Wabash County, Illinois.
The Amended Order is being issued to correct certain errors and make other technical
clarifications to the original Corrective Action Order. The Amended Order amends preliminary
findings 3, 4, 9, 10, 16, and 17, the definition of “Isolated Segment” as applied to the required
corrective actions, and corrective actions 2(d) and 2(j).
Service is being made by certified mail and facsimile. Service of the Amended Order by
electronic transmission is deemed complete upon transmission and acknowledgement of receipt,
or as otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this Amended
Order are effective upon completion of service.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Acting Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Office of
Pipeline Safety, PHMSA
Mr. James Urisko, Regional Director, Southern Region, Office of Pipeline Safety,
PHMSA



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
)
In the Matter of )
)
Marathon Pipe Line, LLC, ) CPF No. 2-2016-5003H
)
Respondent. )
)
AMENDED CORRECTIVE ACTION ORDER
Purpose and Background:
This Amended Corrective Action Order (Order) is being issued under the authority of 49 U.S.C.
§ 60112 to require Marathon Pipe Line, LLC (Marathon or Respondent), to take the necessary
corrective action to protect the public, property, and the environment from potential hazards
associated with the recent failure on its Robinson-Mt. Vernon 10-inch products pipeline.
Marathon operates a 78.4-mile pipeline segment referred to as the Robinson-Mt. Vernon 10-inch
products pipeline (Mt. Vernon Line). The pipeline passes through Crawford, Lawrence, and
Wabash Counties in Illinois and through Gibson and Posey Counties in Indiana, transporting
refined products, a blend of grade gasoline, ultra-low sulfur diesel, and jet fuel, in a batched
system. On April 17, 2016, a reportable accident occurred at the Mt. Vernon Line crossing over
the Wabash River in Wabash County, Illinois (Wabash River Crossing), located between the
Robinson Refinery in Robinson, Illinois, and the Mt. Vernon Station in Mt. Vernon, Indiana.
As of April 22, 2016, Marathon estimated a release of 48,300 gallons of ultra-low sulfur diesel
fuel from the Mt. Vernon Line failure (the Failure). The cause of the Failure has not yet been
determined.
On April 22, 2016, PHMSA issued a Corrective Action Order to Marathon. This Amended
Corrective Action Order replaces and supersedes the CAO issued to Marathon on April 22, 2016.
Pursuant to 49 U.S.C. § 60117, the Office of Pipeline Safety (OPS), PHMSA, initiated an
investigation of the Failure, the preliminary findings of which are as follows.
Preliminary Findings:
1) On the morning of April 17, 2016, a resident on the Illinois side of the Wabash River
observed a sheen on the river water, downstream of the Wabash River Crossing. The
resident notified the Wabash County, Illinois Sheriff’s Department, which in turn,



notified the Mt. Carmel, Illinois, Fire Department at 11:25 a.m., Central Daylight
Time (CDT).
2) The Mt. Carmel Fire Department observed the sheen on the river and, after
reviewing its pipeline maps, notified Marathon at 11:59 a.m.
3) Upon notification, Respondent deployed crews to investigate the reported sheen.
Marathon confirmed the presence of a sheen on the Wabash River and consequently
shut down the Mt. Vernon Line by closing block valve TWRKIRK-MVERBVTR-
22, (TR-22), located in Illinois at milepost (MP) 51.5, at 2:26 p.m. CDT and also
closing block valve TWRILIN-MVERBVTR-23, (TR 23), located Indiana at MP
56.1, at 2:31 p.m. CDT. The segment between these two block valves spans – a
distance of 4.5 miles (Isolated Segment).
4) At 1:54 p.m. CDT on April 17, 2016, Respondent initially reported a sheen on the
Wabash River to the National Response Center (NRC Report No. 1145495). This
NRC report was updated the same day at 10:05 p.m. CDT, reporting the release of
diesel from its pipeline (NRC Report No. 1145511).
5) Respondent estimates 48,300 gallons of ultra-low sulfur diesel fuel have been
released as a result of the Failure. Marathon also reported that sheen was discovered
at the confluence of the Wabash and Ohio Rivers. Marathon deployed five Shoreline
Cleanup and Assessment Technique (SCAT) teams.
6) On April 17, 2016, Respondent’s personnel also attempted boom deployment but
were hampered by high water levels and high river velocity. Marathon also
dispatched an aerial patrol to determine the extent of the sheen, and began setting up
its unified incident command center in Grayville, IL.
7) The Mt. Vernon Line is a single 10-inch diameter products pipeline that transports
refined products, a blend of grade gasoline, ultra-low sulfur diesel, and jet fuel, in a
batched system. The pipeline originates at the Robinson Refinery in Robinson,
Illinois, and terminates at the Mt. Vernon station in Mt. Vernon, Indiana, a distance
of approximately 78.4 miles (Affected Segment).
8) The Failure occurred on the Affected Segment on the Mt. Vernon Line, at the
Wabash River Crossing near milepost (MP) 53.2 (Failure Site).
9) The Affected Segment was constructed in 1951 and consists of 10-inch diameter,
0.307” wall thickness, Grade API 5L X42 Low-Frequency Electric Resistance
Welded (LF-ERW) seam pipe. The Affected Segment also has a coal tar coating and
an impressed current cathodic protection (CP) system. The manufacturer of the
pipeline is unknown.
10) The maximum operating pressure (MOP) of Respondent’s Mt. Vernon Line is 1,359
pounds per square inch (psig), as established by an 11-hour hydrostatic test in



August 2015. At the time of the Failure, the Mt. Vernon Line was operational but no
product was flowing through the pipeline.
11) Marathon asserts that cessation of operation of the Mt. Vernon Line occurred for
reasons unrelated to the Failure.
12) On April 17, 2016, at a site close to the Wabash River Crossing where the sheen had
been observed, Respondent took water samples to confirm concentration of
petroleum product in the water, and deployed divers to assess the condition of the
Mt. Vernon Line.
13) Respondent’s divers found that approximately 60 feet of the Mt. Vernon Line was
exposed and no longer covered by the river bottom. Additionally, portions of the 60-
foot segment of exposed pipeline were not supported by the river bottom.
14) Respondent injected the Mt. Vernon Line with water to determine if the line would
hold pressure. The water-injection test revealed that the pipeline was not holding
pressure.
15) Further, during this water-injection test, Respondent’s employees and PHMSA OPS
personnel observed bubbles in the water over the pipeline, as well as an increase in
diesel smell. Respondent’s employees and PHMSA OPS personnel believed the
bubbles and smell collectively indicated a leak in the Mt. Vernon Line.
16) Marathon reported to PHMSA that it believes the leak started on the Mt Vernon line
around 3:00 a.m. CDT on April 17, 2016, at a small leak rate – the pressure on the
Mt. Vernon Line was 191 psig.
17) Respondent notes the leak on the Mt. Vernon Line worsened over time because at
approximately 5:00 a.m. CDT on April 17, 2016, the pressure calculated at 73 psig.
18) Marathon partnered with the U.S. Environmental Protection Agency, Illinois
Environmental Protection Agency, the Illinois Emergency Management Agency, the
Indiana Department of Environmental Management, the U.S. Coast Guard, and
PHMSA to establish a Unified Command in order to more effectively respond to the
Failure.
19) There were no impacts to life or property as a result of the Failure.
20) The cause of the Failure is unknown, and therefore it is also unknown if the
conditions that led to the Failure on the Isolated Segment are also present on the
Affected Segment. While the investigation is ongoing, the Mt. Vernon Line remains
out of service.
21) Marathon has not yet developed a repair plan for the Isolated Segment, but is
considering horizontally directionally drilling a new pipe section at the Wabash
River Crossing as an alternative to repairing the failed line.



22) Respondent also operates a 6-inch line that runs from Kirkwood Station, Illinois, to
Mt. Vernon Terminal, Indiana, a distance of approximately 57.3 miles. This line
runs parallel to the Mt. Vernon Line and also crosses the Wabash River at MP 53.2.
This line was abandoned in 1984 and Respondent asserts it was not a factor in the
Failure.
Determination of Necessity for Corrective Action Order and Right to Hearing:
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, after reasonable notice and the opportunity for a hearing, requiring corrective action,
which may include the suspended or restricted use of a pipeline facility, physical inspection,
testing, repair, replacement, or other action, as appropriate. The basis for making the
determination that a pipeline facility is or would be hazardous, requiring corrective action, is set
forth both in the above-referenced statute and 49 C.F.R. § 190.233, a copy of which is enclosed.
Section 60112 and the regulations promulgated thereunder provide for the issuance of a
Corrective Action Order, without prior notice and opportunity for hearing, upon a finding that
failure to issue the Order expeditiously would result in the likelihood of serious harm to life,
property, or the environment. In such cases, an opportunity for a hearing and expedited review
will be provided as soon as practicable after the issuance of this Order.
After evaluating the foregoing preliminary findings of fact, I find that continued operation of the
Affected Segment without corrective measures is or would be hazardous to life, property, or the
environment. Additionally, the Mt. Vernon Line was constructed in 1952 of low frequency
ERW pipe, a known threat to pipeline integrity under certain conditions, and is used to transport
products of a hazardous nature. Further, there is soil and water contamination in the vicinity and
downstream of the Failure Site, the cause of the Failure is still unknown, and therefore it also
unknown if the conditions that led to the Failure on the Isolated Segment are present on the
Affected Segment. Last, there is still an ongoing investigation to determine the cause of the
Failure. Based on these factors, I find that a failure to issue this Order expeditiously to require
immediate corrective action would result in the likelihood of serious harm to life, property, or the
environment.
Accordingly, this Order mandating immediate corrective action is issued without prior notice and
opportunity for a hearing. The terms and conditions of this Order are effective upon receipt.
Within 10 days of receipt of this Order, Respondent may contest its issuance obtain expedited
review either by answering in writing or requesting a hearing under 49 C.F.R. § 190.211, to be
held as soon as practicable under the terms of such regulation, by notifying the Associate
Administrator for Pipeline Safety in writing, with a copy to the Director, Southern, PHMSA
(Director). If Respondent requests a hearing, it will be held telephonically or in-person in
Southern Region office or Washington, D.C.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. In that event, PHMSA will notify
Respondent of any additional measures that are required and an amended Order issued, if



necessary. To the extent consistent with safety, Respondent will be afforded notice and an
opportunity for a hearing prior to the imposition of any additional corrective measures.
Required Corrective Actions:
Pursuant to 49 U.S.C. § 60112, I hereby order Marathon to immediately take the following
corrective actions for the Affected Segment and Isolated Segment:
Definitions:
The term “Affected Segment” means Respondent’s Robinson-Mt. Vernon 10-inch products
pipeline, (Mt. Vernon Line), originating at the Robinson Refinery in Robinson, Illinois and
terminating at the Mt. Vernon station in Mt. Vernon, Indiana, a distance spanning approximately
78.4 miles.
The term “Isolated Segment” means the section on Respondent’s Mt. Vernon line between block
valve TWRKIRK-MVERBVTR-22, (TR-22), located in Illinois at milepost (MP) 51.5, and
block valve TWRILIN-MVERBVTR-23, (TR 23), located Indiana at MP 56.1. The segment
between these two block valves spans – a distance of 4.5 miles.
The term “Director” means Director, Southern Region, PHMSA.
The term “Failure Site” means the affected Segment on Respondent’s Mt. Vernon line, at the
Wabash River crossing near milepost (MP) 53.2
1. Shutdown of Pipeline. Marathon must not operate the Isolated Segment until authorized to
do so by the Director.
2. Restart Plan. Prior to resuming operation of the Isolated Segment, Marathon must develop
and submit a written Restart Plan to the Director for prior approval.
a. The Director may approve the Restart Plan in
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