# MARATHON PIPE LINE LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 320075024
- **title:** MARATHON PIPE LINE LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-09-05
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.412(a), 195.420(a), 195.563(a), 195.575, 195.579, 195.583.
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320075024
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320075024
**body:**

Notice of Probable Violation involving MARATHON PIPE LINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.412(a),  195.420(a),  195.563(a),  195.575,  195.579,  195.583. The case was opened on 2007-09-05 and is reported as closed as of 2008-11-07. Proposed civil penalty: $82,000. Assessed civil penalty: $82,000. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320075024_FinalOrder_11072008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320075024/320075024_FinalOrder_11072008.pdf

320075024_finalorder_11072008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320075024/320075024_finalorder_11072008_text.pdf

320075024_NOPV PCP_09052007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320075024/320075024_NOPV%20PCP_09052007.pdf

320075024_nopv pcp_09052007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320075024/320075024_nopv%20pcp_09052007_text.pdf

320075024_operator response_10012007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320075024/320075024_operator%20response_10012007.pdf

320075024_finalorder_11072008_text.pdf

U S Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Ave S E
Washington DC 20590
NQV 7 ~X~
Mr. Craig O. Pierson
Vice President of Operations
Marathon Pipe Line, LLC
539 South Main Street
Findlay, OH 45840
Re: CPF No. 3-2007-5024
Dear Mr. Pierson:
Enclosed is the Final Order issued in the above-referenced case. It makes findings of
violation and assesses a civil penalty of $82, 000. I acknowledge receipt of your wire transfer of
$82, 000 on September 26, 2007, and accept it as payment in full of the civil penalty assessed
herein. This case is now closed, Your receipt of the Final Order constitutes service of that
document 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: Ivan Huntoon
Director, Central Region, PHMSA
CERTIFIED MAIL — RETURN RECEIPT RE UESTED



U. S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
In the Matter of
Marathon Pipe Line, LLC,
Respondent.
CPF No. 3-2007-5024
FINAL ORDER
From April 2006 to February 2007, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to 49 U. S. C. $ 60117, inspected the hazardous liquid
pipeline facilities and records of Marathon Pipe Line, LLC (Marathon or Respondent) in Ohio,
Michigan, Indiana and Illinois. These facilities constitute a portion of Marathon's pipeline
system, which includes more than 5, 000 miles of hazardous liquid and natural gas pipelines in 15
states. On September 5, 2007, in accordance with 49 C. F. R. ( 190. 207, the Director, Central
Region, Pipeline and Hazardous Materials Safety Administration (Director), issued to
Respondent a Notice of Probable Violation and Proposed Civil Penalty (Notice) following said
inspections. The Notice proposed finding that Marathon had committed certain violations of 49
C, F. R, Part 195 and assessing a civil penalty of $82, 000 for the alleged violations.
Respondent responded to the Notice by letter dated October 1, 2007 (Response). Marathon did
not contest the allegations in the Notice and submitted a wire transfer in the amount of the
proposed civil penalty ($82, 000), thereby waiving further rights to respond and authorizing the
entry of this Final Order.
Pursuant to 49 C. F. R. ) 190. 213 and 49 U. S. C. ( 60122, I hereby find that Respondent violated
the following sections of 49 C. F. R. Part 195, as more fully described in the Notice:
Item 1. The Notice alleged that Respondent violated 49 C. F. R. $ 195. 412(a),
which states:
g 195. 412 Inspection of rights-of-way and crossings under navigable
waters.



(a) Each operator shall, at intervals not exceeding 3 weeks, but at least
26 times each calendar year, inspect the surface conditions on or adjacent to
each pipeline right-of-way. Methods of inspection include walking, driving,
flying or other appropriate means of traversing the right-of-way.
Specifically, Item 1 alleged that Respondent violated 49 C. F. R. $ 195. 412(a) by failing to
inspect the surface conditions along Marathon's RIO product pipeline system, which runs
from Robinson to Lima, in certain specified areas in Carmel, Indiana. Respondent's use of
aerial patrolling was ineffective due to vegetation overgrowth,
Item 3. The Notice alleged that Respondent violated 49 C. F. R. ( 195. 563(a), which states:
g 195. 563 Which pipelines must have cathodic protection?
(a) Each buried or submerged pipeline that is constructed, relocated,
replaced, or otherwise changed after the applicable date in $195. 401(c) must
have cathodic protection. The cathodic protection must be in operation not later
than 1 year after the pipeline is constructed, relocated, replaced, or otherwise
changed, as applicable.
Specifically, Item 3 of the Notice alleged that Respondent violated 49 C. F. R. $195. 563(a) by
failing to provide cathodic protection on a new section of pipeline running between the relief
valve manifold and relief tank number 2003 at Marathon's refinery in Robinson, Illinois, within
one year of construction. The new line section was placed into service on July 14, 2005, but
cathodic protection was not put in place until July 28, 2006.
Item 5. The Notice alleged that Respondent violated 49 C. F. R. )) 195. 589(c), 195. 569, and
195. 579(c) which state:
g 195. 5S9 What corrosion control information do I have to maintain?
(a) ""
(c) You must maintain a record of each analysis, check, demonstration,
examination, inspection, investigation, review, survey, and test required by
this subpart in sufficient detail to demonstrate the adequacy of corrosion
control measures or that corrosion requiring control measures does not exist.
You must retain these records for at least 5 years, except that records related
to ) $195. 569, 195. 573(a) and (b), and 195. 579(b)(3) and (c) must be retained
for as long as the pipeline remains in service.
g 195. 569 Do I have to examine exposed portions of buried pipelines?
Whenever you have knowledge that any portion of a buried pipeline is
exposed, you must examine the exposed portion for evidence of external
corrosion if the pipe is bare, or if the coating is deteriorated. If you find
external corrosion requiring corrective action under $195. 585, you must
investigate circumferentially and longitudinally beyond the exposed portion



(by visual examination, indirect method, or both) to determine whether
additional corrosion requiring remedial action exists in the vicinity of the
exposed portion.
g 195. 579 What must I do to mitigate internal corrosion?
(a) ""
(c) Removing pipe Whenever you remove pipe from a pipeline, you
must inspect the internal surface of the pipe for evidence of corrosion. If you
find internal corrosion requiring corrective action under $195. 585, you must
investigate circumferentially and longitudinally beyond the removed pipe (by
visual examination, indirect method, or both) to determine whether additional
corrosion requiring remedial action exists in the vicinity of the removed pipe.
Specifically, Item 5 of the Notice alleged that Respondent failed to properly document corrosion
inspections on a portion of the Princeton — Robinson 4" LPCJ pipeline that was exposed on or
about April 18, 2005, and on pipe removed at the Harpster pump station during a 2005 upgrade.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
Having reviewed the record and considered the assessment criteria, I hereby assess Respondent a
civil penalty of $82, 000, which amount has already been paid by Respondent.
WARNING ITEMS
With respect to Items 2, 4 and 6, the Notice alleged probable violations of Part 195 but did not
propose a civil penalty or compliance order for these items. Therefore, they are considered to be
warning items. The warnings were for:
49 C. F. R. ) 195. 420(a) (Notice Item 2) — alleged failiue to maintain a valve
necessary for the safe operation of a pipeline in good working order at all times.
The AMO main line block valve on the RIO pipeline failed to close on December
8, 2006;
49 C. F. R. $ 195. 575 (Notice Item 4) — alleged failure to electrically test each
electrical isolation. Respondent did not obtain electrical readings at casings
located at Milepost 1561+66 on the RIO pipeline and Milepost 3771+84 on the
22" crude oil pipeline; and
49 C. F. R. $ 195. 583 (Notice Item 6) — alleged failure to fully inspect each portion
of its pipeline that is exposed to the atmosphere for evidence of atmospheric
corrosion. Respondent failed to identify certain areas as requiring periodic
atmospheric corrosion inspections and in one instance performed an inadequate
inspection.



In its Response, Marathon described actions it had initiated to address the cited items.
Having considered such information, I find, pursuant to 49 C. F. R. ) 190. 205, that
probable violations of 49 C. F. R. $$ 195. 420(a), 195. 575, and 195, 583 occurred and
Respondent is hereby advised to correct such conditions. In the event that PHMSA finds
a violation for any of these items in a subsequent inspection, Respondent may be subject
to future enforcement action.
The terms and conditions of this Final Order shall be effective upon receipt.
g ~ (f ~
NOV 7 2008
Date Issued
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
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