# MARATHON PIPE LINE LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 320125008
- **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:** 2012-04-26
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.402(a), 195.402(c)(12), 195.404(a), 195.412(a), 195.420(b), 195.428(a), 195.56(a), 195.567(a), 195.583(b).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-320125008.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-320125008.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320125008
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320125008
**body:**

Notice of Probable Violation involving MARATHON PIPE LINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(12),  195.404(a),  195.412(a),  195.420(b),  195.428(a),  195.56(a),  195.567(a),  195.583(b). The case was opened on 2012-04-26 and is reported as closed as of 2016-06-03. Proposed civil penalty: $135,500. Assessed civil penalty: $135,500. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320125008_Closure Letter_06032016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320125008/320125008_Closure%20Letter_06032016.pdf

320125008_Closure Letter_06032016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320125008/320125008_Closure%20Letter_06032016_text.pdf

320125008_Final Order_07082014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320125008/320125008_Final%20Order_07082014.pdf

320125008_Final Order_07082014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320125008/320125008_Final%20Order_07082014_text.pdf

320125008_Operator Response and Request for Time Extension_06012012.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320125008/320125008_Operator%20Response%20and%20Request%20for%20Time%20Extension_06012012.pdf

320125008_Closure Letter_06032016_text.pdf

CERTIFIED MAIL - RETURN RECEIPT REQUESTED
June 3, 2016
Mr. Craig O. Pierson
President
Marathon Pipeline, LLC
539 South Main Street
Findlay, OH 45840
RE: CPF 3-2012-5008
Dear Mr. Pierson:
On July 8, 2014, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued
to Marathon Pipeline, LLC, a Final Order in the above-referenced case. This Order included a
Compliance Order and Civil Penalty assessment. Based on our review of the documentation
you provided and confirmation of payment of the civil penalty, it has been determined that you
have complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration

320125008_Final Order_07082014_text.pdf

JULY 8, 2014
Mr. Craig O. Pierson
President
Marathon Pipe Line, LLC
539 South Main Street
Findlay, OH 45840
Re: CPF No. 3-2012-5008
Dear Mr. Pierson:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $135,500, and specifies actions that need to be taken by
Marathon Pipeline, LLC, to comply with the pipeline safety regulations. The penalty payment
terms are set forth in the Final Order. When the civil penalty has been paid and the terms of the
compliance order completed, as determined by the Director, Central Region, this enforcement
action will be closed. Service of the Final Order by certified mail is deemed effective upon the
date of mailing, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Jeffrey D. Wiese
Associate Administrator
for Pipeline Safety
Enclosure
cc: Ms. Linda Daugherty, Director, Central Region, OPS
CERTIFIED MAIL - RETURN RECEIPT REQUESTED



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Marathon Pipe Line, LLC, ) CPF No. 3-2012-5008
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
From July 12 through December 3, 2010, pursuant to 49 U.S.C. § 60117, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an on-site pipeline safety inspection of the facilities and records of Marathon
Pipe Line, LLC (Marathon or Respondent), in the Ohio area. Marathon and Ohio River Pipe
Line, LLC, own a network of pipeline systems, including approximately 962 miles of common-
carrier crude oil pipelines and approximately 1,819 miles of common-carrier product pipelines
extending across nine states.1
As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,
by letter dated April 26, 2012, a Notice of Probable Violation, Proposed Civil Penalty, and
Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice
proposed finding that Marathon had committed various violations of 49 C.F.R. Part 195 and
assessing a civil penalty of $135,500 for the alleged violations. The Notice also proposed
ordering Respondent to take certain measures to correct the alleged violations.
Marathon responded to the Notice by letter dated June 1, 2012 (Response). The company
contested several of the allegations, offered additional information in response to the Notice, and
requested that the proposed civil penalty be reduced. Marathon also proposed a compromise
penalty offer of $30,000. Respondent did not request a hearing and therefore has waived its right
to one.
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Part 195.402, as follows:
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), which states:
1 http://www.marathonpipeline.com/Who We Are/Investor Information/ (last accessed December 6, 2013).



2
§ 195.402 Procedural manual for operations, maintenance, and
emergencies.
(a) General. Each operator shall prepare and follow for each
pipeline system a manual of written procedures for conducting normal
operations and maintenance activities and handling abnormal operations
and emergencies. This manual shall be reviewed at intervals not exceeding
15 months, but at least once each calendar year, and appropriate changes
made as necessary to insure that the manual is effective. This manual shall
be prepared before initial operations of a pipeline system commence, and
appropriate parts shall be kept at locations where operations and
maintenance activities are conducted.
The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) by failing to follow its own
manual of written procedures for designating mainline valves and conducting normal operations
and maintenance activities on those valves. Specifically, the Notice alleged that Marathon failed
to properly classify certain valves as mainline valves, based on its own definition of a mainline
valve set forth in the company’s procedure MPLMNT115, Section 7.1; therefore, Marathon did
not properly designate nine of its mainline valves for inspection twice each calendar year but not
to exceed 15 months.
In its Response, Marathon contested this allegation, arguing that a review of the nine valves
listed in the Notice would indicate that six were, in fact, not mainline valves and therefore not
subject to the twice-yearly inspection requirement. The company asserted that the following
valves were properly identified as non-mainline valves: VALV – 02065 PL1 pig trap on the
Woodriver-to- Clermont line; VALV – 020566 HWRT valve on the pig trap; valve at the
Explorer station on the lateral line valve; the valve on the pig launcher at Martinsville 6751 + 39
MLV; and the valves inside of Marathon’s Speedway Station.2
Upon review of the diagrams provided by Marathon of VALV-02065 PLI pig trap on the
Woodriver-to-Clermont line, the VALV-020566 HWRT valve on the pig trap, and the valves
inside the Speedway Station, it is apparent that those valves were capable of full-volume flow off
the mainline and used to isolate mainline sections because they were the last shutoff valves
before the pig trap. Most trap isolation and bypass valves are the first line of defense in the event
of an emergency. Further, the valve on the pig launcher at Martinsville 6751 + 39 MLV was also
capable of full-volume flow off the mainline and used to isolate the mainline valve because it
2 Marathon defined “Mainline valve” and Non-mainline valve” in MPLMNT115 as follows:
“Mainline valves are valves capable of full volume flow of the mainline which: (1) are
used to isolate mainline sections or (2) are the first valve off the mainline in a lateral line
used to isolate the mainline from other facilities (i.e. pump station, tank farm, low
pressure manifold, etc.).
Non-mainline valves are capable of full volume flow of the mainline and are located
within a facility that is isolated by the mainline valves that are located within or directly
adjacent to the facility (station, junction, etc.). Examples of non-mainline valves include
but are not limited to unit suction, unit discharge, bypass, control, manifold, and tank
valves.”



3
was the final isolation valve before the lateral valves. I am unable to provide an analysis of the
valve at the Explorer station because the diagram provided by the operator in its Response is
illegible. Therefore, I am withdrawing this one instance of violation involving the Martinsville
pig launcher valve. As for the remaining violations, the evidence supports the allegations of
violation set forth in the Notice. Accordingly, after considering all of the evidence, I find that
Marathon violated 49 C.F.R. § 195.402(a) by failing to follow its own written procedures for
designating mainline valves and conducting normal operations and maintenance activities on
those valves.
Item 5: The Notice alleged that Respondent violated 49 C.F.R. § 195.404(a), which states:
§ 195.404 Maps and records.
(a) Each operator shall maintain current maps and records of its
pipeline systems that include at least the following information:
(1) Location and identification of the following pipeline facilities:
(i) Breakout tanks;
(ii) Pump stations;
(iii) Scraper and sphere facilities;
(iv) Pipeline valves;
(v) Facilities to which § 195.402(c)(9) applies;
(vi) Rights-of-way; and
(vii) Safety devices to which § 195.428 applies.
The Notice alleged that Respondent violated 49 C.F.R. § 195.404(a) by failing to maintain
current maps of its pipeline systems. Specifically, the Notice alleged that Marathon’s
Geographic Information Systems alignment sheets were developed with the c onstruction
inventories and had not been proofed or updated by field personnel since 1999. The Notice
alleged that the company’s alignment sheets showed a number of errors, including elevations,
legends, valve locations, pipe coating, pipe wall thickness and grade.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 195.404(a) by failing to maintain
current maps of its pipeline systems.
Item 7: The Notice alleged that Respondent violated 49 C.F.R. § 195.420(b), which states:
§ 195.420 Valve maintenance.
(a) . . .
(b) Each operator shall, at intervals not exceeding 7½ months, but at
least twice each calendar year, inspect each mainline valve to determine
that it is functioning properly.
The Notice alleged that Respondent violated 49 C.F.R. § 195.420(b) by failing to inspect each
mainline valve at intervals not exceeding 7½ months, but at least twice each calendar year.
Specifically, the Notice alleged that Marathon inspected VALV – 103404 VDC Philips Junction
MLV 15 only once in the 2008, 2009, and 2010 calendar years. In addition, it alleged that



4
VALV HG17 was inspected only once in 2009 and not inspected at all in 2010.
Respondent did not contest this allegation of violation but requested a reduction of the proposed
penalty, which I will address in the Assessment of Penalties section below. Accordingly, based
upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.420(b) by
failing to inspect each mainline valve at intervals not exceeding 7½ months, but at least twice
each calendar year.
Item 8: The Notice alleged that Respondent violated 49 C.F.R. § 195.428(a), which states:
§ 195.428 Overpressure safety devices and overfill protection systems.
(a) Except as provided in paragraph (b) of this section, each operator
shall, at intervals not exceeding 15 months, but at least once each calendar
year, or in the case of pipelines used to carry highly volatile liquids, at
intervals not to exceed 7½ months, but at least twice each calendar year,
inspect and test each pressure limiting device, relief valve, pressure
regulator, or other item of pressure control equipment to determine that it
is functioning properly, is in good mechanical condition, and is adequate
from the standpoint of capacity and reliability of operation for the service
in which it is used.
The Notice alleged that Respondent violated 49 C.F.R. § 195.428(a) by failing to inspect and test
each relief valve, at intervals not exceeding 15 months, to determine that it was functioning
properly, was in good mechanical condition, and was adequate from the standpoint of capacity
and reliability of operation for the service in which it was used. Specifically, the Notice alleged
that Marathon did not inspect all thermal relief valves at the Harrison, East Spartan, Robinson,
and Louisville stations. Additionally, inspections at Patoka, Martinsville, Clermont, and Findlay
RV6 exceeded the 15-month maximum interval by five days, from April 8, 2008, to July 13,
2009.
In its Response, Marathon admitted it had failed to inspect all of the valves at the Louisville
Station and had improperly numbered the valves at Wood River. Respondent also claimed that it
did not operate the Harrison location and provided evidence that it had timely inspected the
valves at Findlay RV6. Marathon argued that it had not been provided with sufficient
information to determine the validity of the remaining claims for the East Sparta, Robinson,
Patoka, Martinsville, and Clermont locations.
Based on the evidence that the Respondent has provided, it appears that Marathon did timely
inspect the valves at Findlay RV6 and that it did not own the Harrison location. As for its
argument about insufficient information as to the remaining claims, as noted in the Violation
Report, the devices were not uniquely numbered by Marathon; therefore, the Notice could not
identify which specific valves were not inspected. Moreover, exit interviews with Marathon
personnel indicated that the company did not consider certain safety valves to be jurisdictional to
the U.S. Department of Transportation and therefore were not inspected. In order to maintain
compliance with the regulations, an operator must not only perform the required inspections but
be able to present evidence during the inspection that it has complied.



5
Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.
§ 195.428(a) by failing to inspect and test each relief valve at intervals not exceeding 15 months
to determine that it was functioning properly, was in good mechanical condition, and was
adequate from the standpoint of capacity and reliability of operation for the service in which it
was used.
Item 9: The Notice alleged that Respondent violated 49 C.F.R. § 195.567(a), which states:
§ 195.567 Which pipelines must have test leads and what must I do to
install and maintain the leads?
(a) General. Except for offshore pipelines, each buried or submerged
pipeline or segment of pipeline under cathodic protection required by this
subpart must have electrical test leads for external corrosion control.
However, this requirement does not apply until December 27, 2004 to
pipelines or pipeline segments on which test leads were not required by
regulations in effect before January 28, 2002.
The Notice alleged that Respondent violated 49 C.F.R. § 195.567(a) by failing to have electrical
test leads for external corrosion control on each pipeline segment under cathodic protection.
Specifically, it alleged that Marathon systematically incorporated a significant number of
operational bonds for connecting multiple segments of pipeline together to protect the system as
a whole, but failed to install test leads for each segment.
Respondent did not contest this allegation. Accordingly, based upon a review of all of the
evidence, I find that Respondent violated 49 C.F.R. § 195.567(a) by failing to have electrical test
leads for external corrosion control on each pipeline segment under cathodic protection.
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.
ASSESSMENT OF PENALTIES
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed
$100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any
related series of violations. In determining the amount of a civil penalty under
49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,
circumstances, and gravity of the violation, including adverse impact on the environment; the
degree of Respondent’s culpability; the history of Respondent’s prior offenses; the Respondent’s
ability to pay the penalty and any effect that the penalty may have on its ability to continue doing
business; and the good faith of Respondent in attempting to comply with the pipeline safety
regulations. In addition, I may consider the economic benefit gained from the violation without
any reduction because of subsequent damages, and such other matters as justice may require.
The Notice proposed a total civil penalty of $135,500 for the violations cited above.
Item 2: The Notice proposed a civil penalty of $63,200 for Respondent’s violation of



6
49 C.F.R. § 195.402(a), for failing to follow its own written procedures for designating mainline
valves and conducting normal operations and maintenance activities on those valves. As
discussed above, I found that the valves in question did, in fact, meet Marathon’s own definition
of mainline valves. Respondent requested a penalty reduction based upon its good-faith belief
that some of the cited valves were not mainline valves. However, as discussed above, Marathon
failed to follow its own procedures in how such valves should be classified. The timely
inspection for these valves is critical to the safe operation of the pipeline system since they
provide the first line of defense in the event of an emergency. I am not convinced that a
misidentification of the valves based on its own procedures entitles Marathon to a penalty
reduction based on a good-faith mistake in its interpretation of a regulatory requirement.
As for the single instance discussed above, where one charge was withdrawn based on the
illegibility of the document provided by Marathon, I have reviewed the penalty assessment
criteria and calculation for this Item and find that withdrawal of this single charge would not
affect the penalty as originally proposed. Accordingly, having reviewed the record and
considered the assessment criteria, I assess Respondent a civil penalty of $63,200 for violation of
49 C.F.R. § 195.402(a).
Item 5: The Notice proposed a civil penalty of $26,000 for Respondent’s violation of
49 C.F.R. § 195.404(a), for failing to maintain current maps of its pipeline systems. Marathon
neither contested the allegation nor presented any evidence or argument justifying a reduction in
the proposed penalty. Accordingly, having reviewed the record and considered the assessment
criteria, I assess Respondent a civil penalty of $26,000 for violation of 49 C.F.R. § 195.404(a).
Item 7: The Notice proposed a civil penalty of $46,300 for Respondent’s violation of
49 C.F.R. § 195.420(b), for failing to inspect each mainline valve twice each calendar year at
intervals not exceeding 7½ months. Marathon did not contest the allegation of violation but
sought a lower penalty of $12,000 for two reasons. First, the company claimed to have now
inspected all of the mainline valves in question and that “they have successfully passed
inspection on a semi-annual basis….” Second, Marathon asserted that the valves “are not
located in remote or isolated locations” and “have not and do not present significant safety
risks.”3
Under PHMSA’s standard penalty assessment criteria, I see no reason to reduce the proposed
penalty. Respondent's failure to properly inspect these mainline valves placed the safety of its
pipeline at risk, as well as that of the public, property, and the environment in the vicinity of the
pipeline. Fully functioning valves are extremely important to mitigate damage during an
emergency, as mainline valves can be closed to isolate part of a pipeline system and limit the
volume of product released in the event of a spill.
Neither does the fact that the valves were successfully tested after the PHMSA inspection and
found to be in good working order support a reduction. In applying the penalty assessment
criteria, PHMSA does not make deductions for subsequent inspections or tests that turn out to be
satisfactory or to show compliance. Such an approach would undermine any incentive for
operators to conduct routine inspections properly and that play an integral part in normal
3 Response at 4.



7
operations and maintenance. Although, PHMSA appreciates the efforts by Marathon after the
Notice was issued, the proposed penalty reflects the company’s failure to conduct required
inspections prior to the PHMSA inspection. Accordingly, having reviewed the record and
considered the assessment criteria, I assess Respondent a civil penalty of $46,300 for violation of
49 C.F.R. § 195.420(b).
In summary, having reviewed the record and considered the assessment criteria for each of the
Items cited above, I assess Respondent a total civil penalty of $135,500.
Payment of the civil penalty must be made within 20 days of service. Federal regulations
(49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal
Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed
instructions are contained in the enclosure. Questions concerning wire transfers should be
directed to: Financial Operations Division (AMZ-341), Federal Aviation Administration, Mike
Monroney Aeronautical Center, P.O. Box 269039, Oklahoma City, Oklahoma 73125. The
Financial Operations Division telephone number is (405) 954-8893.
Failure to pay the $135,500 civil penalty will result in accrual of interest at the current annual
rate in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to
those same authorities, a late penalty charge of six percent (6%) per annum will be charged if
payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty
may result in referral of the matter to the Attorney General for appropriate action in a district
court of the United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 2, 5, 8 and 9 in the Notice for
violations of 49 C.F.R. §§ 195.402(a), 195.404(a), 195.428(a) and 195.567(a), respectively.
Under 49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids
or who owns or operates a pipeline facility is required to comply with the applicable safety
standards established under chapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and
49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance
with the pipeline safety regulations applicable to its operations:
1. With respect to the violation of § 195.402(a) (Item 2), Respondent must apply its
definitions of “mainline” and “non-mainline valves” to all valves on its pipeline
system to determine which additional valves require inspection. Each previously
unidentified valve that meets the definition of “mainline valve” shall be added to the
Marathon valve inspection schedule and inspected.
2. With respect to the violation of § 195.404(a) (Item 5), Respondent must review all
alignment sheets and its GIS system for incorrect or omitted information. Upon
completion, each sheet shall be reviewed for accuracy by the subject matter expert
assigned to the field areas that each sheet represents.



8
3. With respect to the violation of § 195.428(a) (Item 8), Respondent must review
its facilities, identify all thermal relief devices, and uniquely label them. Marathon
shall then inspect each relief valve that is not currently within its inspection cycle to
determine whether it is functioning properly.
4. With respect to the violation of § 195.567(a) (Item 9), pertaining to having test
leads on each segment of pipeline, Marathon must identify and document all locations
of operational bonds. This identification will reveal the location of each segment of
pipeline. Marathon must then ensure that each segment has a corresponding test lead.
For segments identified as lacking test leads, the company shall install proper test
leads.
5. Marathon shall perform the compliance requirements above within 180 days of
receipt of the Final Order. The Director may extend the deadline based on a written
request justifying an extension for good cause.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
Failure to comply with this Order may result in the administrative assessment of civil penalties
not to exceed $200,000 for each violation for each day the violation continues or in referral to the
Attorney General for appropriate relief in a district court of the United States.
WARNING ITEMS
With respect to Items 1, 3, 4, 6, and 10, the Notice alleged probable violations of Part 195 but did
not propose a civil penalty or compliance order for these items. Therefore, these are considered
to be warning items. The warnings were for:
49 C.F.R. § 195.56 (Item 1) ─ Respondent’s alleged failure to report a safety-
related condition within five working days after the day a representative of the
operator first determines that the condition exists, but not later than 10 working
days after discovery;
49 C.F.R. § 195.402(a) (Item 3) ─ Respondent’s alleged failure to review its
procedural manual for operations, maintenance, and emergencies, at intervals not
exceeding 15 months;
49 C.F.R. § 195.56(a)(12) (Item 4) ─ Respondent’s alleged failure to establish
and maintain liaison with fire, police, and other appropriate public officials to
learn the responsibility and resources of each government organization that may
respond to a hazardous liquid or pipeline emergency;



9
49 C.F.R. § 195.412(a) (Item 6) ─ Respondent’s alleged failure to inspect each
pipeline right-of-way at intervals not exceeding three weeks, but at least 26 times
each calendar year; and
49 C.F.R. § 195.583(b) (Item 10) ─ Respondent’s alleged failure to monitor
atmospheric corrosion control by giving particular attention to pipe at soil-to-air
interfaces and under disbanded coatings.
Marathon presented information in its Response showing that it had taken certain actions to
address the cited items. If OPS finds a violation of any of these items in a subsequent inspection,
Respondent may be subject to future enforcement action.
Under 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of
this Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline
Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC
20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA
will accept petitions received no later than 20 days after receipt of service of this Final Order by
the Respondent, provided they contain a brief statement of the issue(s) and meet all other
requirements of 49 C.F.R. § 190.215. The filing of a petition automatically stays the payment of
any civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all
other terms and conditions of this Final Order are effective upon service in accordance with
49 C.F.R. § 190.5.
___________________________________ __________________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety
- **truncated:** false
- **body characters:** 28150