{"operation":"document","citation":"CPF 320145005H","title":"MARATHON PIPE LINE LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2014-07-24","effective_on":null,"summary":"CLOSED corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320145005h.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320145005h.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320145005h","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320145005H","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 2014-07-24 and is reported as closed as of 2017-08-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320145005H_Closure Letter_08042017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145005H/320145005H_Closure%20Letter_08042017.pdf\n\n320145005H_Closure Letter_08042017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145005H/320145005H_Closure%20Letter_08042017_text.pdf\n\n320145005H_Corrective Action Order_07242014.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145005H/320145005H_Corrective%20Action%20Order_07242014.pdf\n\n320145005H_Corrective Action Order_07242014_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320145005H/320145005H_Corrective%20Action%20Order_07242014_text.pdf\n\n320145005H_Closure Letter_08042017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 4, 2017\nTimothy J. Aydt\nPresident\nMarathon Pipe Line LLC\n539 South Main Street\nFindlay, Ohio 45840\nCPF 3-2014-5005H\nDear Mr. Aydt:\nOn July 24, 2014, the Pipeline and Hazardous Materials Safety Administration (PHMSA)\nissued to Marathon Pipe Line LLC a Corrective Action Order in the above-referenced case.\nThis Order included a requirement to take corrective actions on your pipeline. Based on our\nreview of the documentation you provided it has been determined that you have complied with\nthe terms of this Order.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\n\n320145005H_Corrective Action Order_07242014_text.pdf\n\nJULY 24, 2014\nVIA CERTIFIED MAIL AND FAX TO: 419-421-3125\nMr. Craig O. Pierson\nPresident\nMarathon Pipe Line LLC\n539 South Main Street\nFindlay, Ohio 45840\nCPF No. 3-2014-5005H\nDear Mr. Pierson:\nEnclosed is a Corrective Action Order. It finds that continued operation of the Marathon Pipe\nLine (MPL) Patoka facility would be hazardous to life, property, and the environment without\nimmediate corrective action. The Corrective Action Order requires you to take certain corrective\nactions to protect the public, property, and the environment in connection with the leak at the\nMPL Patoka Station facility that was reported to the National Response Center on June 29, 2014.\nService is being made by certified mail and facsimile. Your receipt of this Corrective Action\nOrder constitutes service of that document under 49 C.F.R. § 190.5. The terms and conditions of\nthis Order are effective upon receipt.\nWe look forward to the successful resolution of the concerns arising out of this leak to ensure the\nsafe operation of the pipeline systems. Please direct any questions on this matter to Karen\nButler, Supervisor of the Accident Team, Central Region, OPS, at (816) 329-3835.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure: Corrective Action Order and Copy of 49 C.F.R. §190.233\ncc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nMr. Randy Bishop, Regulatory and Compliance Supervisor, Marathon Pipe Line LLC\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 )\nMarathon Pipe Line LLC, ) CPF No. 3-2014-5005H\n)\n)\n)\nRespondent. )\n____________________________________)\nCORRECTIVE ACTION ORDER\nPurpose and Background\nThis Corrective Action Order (Order) is being issued, under authority of 49 U.S.C. § 60112, to\nMarathon Pipe Line LLC (Marathon or Respondent), the operator of the Patoka Station pipeline\nfacility located in Marion County, Illinois. The Patoka Station pipeline facility consists of main\nline, breakout tanks, piping, pumps, equipment, and related support facilities. Marathon also\noperates multiple crude oil pump stations and tank farms throughout the PHMSA Central\nRegion. The Marathon Patoka Station facility receives crude oil from the Roxana to Patoka,\nWoodpat, and Capline Patoka pipelines, stores crude oil in 12 breakout tanks, and transports\ncrude oil on the Patoka to Martinsville, Patoka to Owensboro, and Patoka to Robinson pipelines.\nThis Order finds that continued operation of the Patoka Station facility without corrective action\nwould be hazardous to life, property, or the environment and requires Respondent to take\nimmediate action to ensure the safe operation of the pipeline facility.\nOn June 29, 2014, Respondent reported to the National Response Center a leak at its Patoka\nStation near Patoka, Illinois in Marion County. Respondent estimates the volume of the product\nspill to be approximately 1,126 barrels of crude oil.\nPursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration\n(PHMSA), Office of Pipeline Safety (OPS), initiated an investigation of the failure. OPS\ndetermined that the release originated from the Patoka Station facility, and the apparent cause of\nthe leak is internal corrosion of pipe utilized in moving product in and out of Tank 1284. The\npreliminary findings of the investigation are as follows:\nPreliminary Findings\n• At approximately 04:45 AM CDT on June 29, 2014, Respondent discovered a leak at its\nMarathon Patoka Station facility.\n\n\n\n2\n• A Marathon employee was called out to respond to a high salt-water alarm the morning\nof June 29, 2014, and identified the leak. The employee called back to the control room\nand indicated that a leak was present. The control room shutdown the incoming and\noutgoing pipelines. Employees isolated Tank 1284 and stopped the leak.\n• The leak was reported by Marathon to the National Response Center at 07:13 AM EDT\non June 29, 2014 (NRC report # 1087454).\n• The town of Vernon, Illinois is located approximately 1/4 mile north of the facility and\nthe town of Patoka, Illinois is located 1-1/2 miles south of the facility.\n• The leak occurred at the Marathon Patoka Station facility located in a rural area of South\nCentral Illinois and is adjacent to Illinois State Highway 51. The facility is in an\nUnusually Sensitive Area (USA) associated with drinking water. However, no drinking\nwater is known to have been impacted by the spill.\n• Various state and federal agencies, including the U.S. Environmental Protection Agency,\nassisted with initial activities to contain the crude oil. Those activities included, but were\nnot limited to a road closure, site assessment, and reporting.\n• The spilled amount is reported to be approximately 1,126 barrels. The crude oil covered\na large portion of the Marathon facility and migrated offsite to an Illinois State Highway\n51 roadside ditch.\n• The cause of the leak is under investigation, but appears to be two holes in piping\nassociated with Tank 1284.\n• The leak’s origins are located in a section of 20” diameter, 0.375” wall thickness pipe\ninstalled in 2012. Two holes in the pipe were observed at the 6 o’clock position\napproximately 9 feet apart and involved more than one joint of pipe.\n• Visual examination of the holes suggests internal corrosion as the apparent cause of the\nleaks.\n• Based on PHMSA’s experience with piping involved in internal corrosion failures in\ngeneral, perforations of a 0.375” wall thickness pipe installed in 2012 indicate a very\naggressive corrosion rate.\n• In 2008, PHMSA issued an Advisory Bulletin ADB-08-08 entitled “Proper Identification\nof Internal Corrosion Risk.” In this Advisory Bulletin, PHMSA emphasized to the\nregulated community its responsibilities with respect to determining the need for internal\ncorrosion preventive and mitigative measures.\n• Not including this latest leak at Patoka, since 2008 Marathon has reported to PHMSA six\ncrude oil leaks associated with internal corrosion. These six leaks resulted in the reported\nspill volume of 447 barrels of crude oil.\n• At PHMSA’s request prior to this failure, Marathon Pipe Line, LLC had designed and\ncommitted to engage in an improvement plan for internal corrosion threat mitigation.\nThe implementation of this improvement plan however had not resulted in the direct\nassessment of the area that failed in the Patoka Station.\n\n\n\n3\n• Marathon Pipe Line, LLC has reported a specific leak history of the following at Patoka\nStation:\no 3/26/2012 Seal Failure of 1.6 barrels\no 3/30/2011 Mixer Seal Failure of 0.15 barrels\no 11/10/2004 Bracket weld failure of 38 barrels\no 11/10/2004 Internal Corrosion failure of 40 barrels\no 7/10/2003 Equipment Failure of 10 barrels\n• As a result of a 2013 leak due to internal corrosion of a crude oil relief line at the\nMarathon Martinsville, Illinois facility, Marathon committed to conducting a system-\nwide analysis of the threat of internal corrosion to its facilities and was working on\nupdating internal corrosion plans, procedures, and processes.\n• MPL does have a Direct Assessment program. The failed pipe had not received a Direct\nAssessment survey according to the operator. One other location at the Patoka facility\nhad a repair sleeve installed in May of 2014 (defect was reported to have been found as\n48% thru wall). This repair sleeve was installed as a result of the Direct Assessment\nprogram and improvements as previously committed to PHMSA.\n• The accident investigation is ongoing.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nUnder 49 U.S.C. § 60112 and 49 C.F.R. § 190.233, the Associate Administrator for Pipeline\nSafety (Associate Administrator) may issue a corrective action order after providing reasonable\nnotice and the opportunity for a hearing if he finds that a particular pipeline facility is or would\nbe hazardous to life, property, or the environment. The terms of such an order may include the\nsuspended or restricted use of a pipeline facility, physical inspection, testing, repair, replacement,\nor any other action as appropriate. The Associate Administrator may also issue a corrective\naction order without providing any notice or the opportunity for a hearing if he finds that a\nfailure to do so expeditiously will result in likely serious harm to life, property or the\nenvironment. The opportunity for a hearing will be provided as soon as practicable after the\nissuance of the CAO in such cases.\nAfter evaluating the foregoing preliminary findings of fact, I find that the continued operation of\nthe pipeline without corrective measures would be hazardous to life, property and the\nenvironment. Additionally, after considering the age of the failed pipe and Marathon’s failure\nhistory, circumstances surrounding this leak, the proximity of the pipeline to populated areas,\nwater bodies, drinking water resources, public roadways, and high consequence areas, the\nhazardous nature of the product the pipeline transports, and the ongoing investigation to\ndetermine the cause of the failure, I find that a failure to issue this Order expeditiously to require\nimmediate corrective action would likely result in serious harm to life, property, and the\nenvironment.\nAccordingly, this Corrective Action Order is issued without prior notice and opportunity for a\nhearing. The terms and conditions of this Order are effective upon receipt.\n\n\n\n4\nWithin 10 days of receipt of this Order, Respondent may request a hearing, to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, delivered\npersonally, by mail or by fax at (202) 366-4566. The hearing will be held in Kansas City,\nMissouri, on a date that is mutually convenient to PHMSA and Respondent.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\nadditional measures required and amendment of this Order will be considered. To the extent\nconsistent with safety, Respondent will be afforded notice and an opportunity for a hearing prior\nto the imposition of any additional corrective measures.\nRequired Corrective Action\nPursuant to 49 U.S.C. § 60112, Marathon Pipe Line LLC is ordered to immediately take the\nfollowing corrective actions to ensure the safe operation of the Patoka Station facilities and any\nother facilities determined to be susceptible to internal corrosion:\n1. Within 60 days of receipt of this Order, complete 3rd party mechanical and metallurgical\ntesting and failure analysis of the failed pipe, including analysis of soil samples,\ncorrosion products, and any foreign materials if applicable. The testing and analysis shall\nbe completed as follows:\nA. Document the chain-of-custody when handling and transporting the failed pipe section\nand other evidence from the failure site;\nB. Submit and utilize mechanical and metallurgical testing protocols as approved by the\nDirector, Central Region;\nC. Prior to commencing the mechanical and metallurgical testing, provide the Regional\nDirector with the scheduled date, time, and location of the testing to allow a PHMSA\nrepresentative to witness the testing; and\nD. Ensure that the testing laboratory distributes all resulting reports in their entirety\n(including all media), whether draft or final, to the Regional Director at the same time\nas they are made available to Respondent.\n\n\n\n5\n2. Within 90 days following receipt of this order, submit an Integrity Work Plan (IWP) to\nthe Director, Central Region, OPS for approval. The plan must provide for the\nverification of the integrity of the Patoka Station piping and must address all factors\nknown or suspected in the leak of June 29, 2014, including, but not be limited to the\nintegration of information from the following:\nA. Complete a root cause failure analysis associated with the June 29, 2014 release and\nidentify any contributory causes. Provide, maintain, and submit a project schedule\nassociated with all elements of the internal root cause analysis including but not\nlimited to:\ni. ii. iii. iv. v. Scoping document of the root cause failure analysis;\nInternal procedures associated with root cause failure analysis;\nMultiple methods used to determine root cause and contributory\ncauses, and updates on each method as it progresses;\nList of contributory factors including a review of control room\nactivities for several days prior to the failure, control room activities\nduring the release including completed emergency response, and\ncontrol room associated restart activities; and\nFinal summary of the root cause failure process including any\ninternal lessons learned and if findings are applicable to other\nlocations within the Marathon system.\nB. Perform the integration of the results of the root cause failure analyses and other\nactions required by this Order, with all relevant operating data, including all\nhistorical repair information, construction, operating, maintenance, testing,\nmetallurgical analysis or other third-party consultation information, assessment data\nfor the facility and internal corrosion management processes and documents. Data\ngathering activities must include a review of the failure history of the facility\n(including in-service and pressure test failures) and development of a written report\nto be approved by the Director containing all available information regarding dates\nand causes of leaks and failures.\nC. Perform additional field testing, inspections, and evaluations to determine whether\nand to what extent the conditions associated with this failure are present at other\nfacilities. Include a detailed description of the criteria to be used for the evaluation\nand prioritization of facilities anomalies. Upon completion of testing, inspections,\nand evaluations provide a report for the Director’s approval that summarizes all\ncorrective actions or plans.\n\n\n\n6\n3. Within 90 days of receipt of this Order, review the existing leak detection system\napplicable to Patoka Station facility and identify leak detection enhancements that could\nimprove the facility leak detection response. Include in this review surveillance and\nhazardous vapor monitoring as possible enhancement methods to help immediately\nidentify leaks. Submit for the Director’s approval, a summary report including leak\ndetection enhancement methods for the Patoka Station facility before the facility returns\nto unattended status and the associated implementation schedule.\n4. Within 90 days of the receipt of this Order, review the topography and water runoff\npatterns associated with the Patoka Station and design improvements to mitigate crude\noil migration off site in the event of another facility leak at this location. Submit a\nschedule for implementation to the Regional Director.\n5. Within 6 months of the receipt of this Order, complete an expedited API 653 inspection\non Tank 1284. When performing this tank inspection, take any additional required\nmeasures as may be necessary to sufficiently address metallurgical report findings from\n1A above or API 653 findings from Tank 1285 that is in a similar commodity service.\nReport any findings and identified proposed actions resulting from the API 653\ninspection on Tank 1284 to the Regional Director within 30 days of the completed\ninspection.\n6. Provide quarterly update written reports to the Regional Director on progress regarding\nall elements required in this CAO.\n7. Prior to the failure, the Marathon Patoka facility was not manned 24 hours a day and\nthis could have contributed to the large spill volume. As a condition of the previous\nrestart of the Patoka facility, Marathon agreed to provide 24-hour continuous on-site\nmanned patrolling. This manned patrolling activity shall continue until Marathon has\ndetermined after the execution of the approved IWP that no other Patoka Station piping\nis at risk of an internal corrosion failure. Provide 24 hour advance notification to the\nRegional Director should Patoka Station facility be returned to unmanned operations.\n8. It is requested but not required that Respondent maintain documentation of the costs\nassociated with implementation of this order. Include in each quarterly report the to-\ndate total costs associated with: (1) preparation and revision of procedures, studies and\nanalyses; (2) physical changes to pipeline infrastructure, including repairs, replacements\nand other modifications; and (3) environmental remediation, if applicable.\nThe Director may grant an extension of time for compliance with any of the terms of this Order\nupon a written request timely submitted demonstrating good cause for an extension.\nWith respect to each submission that under this Order requires the approval of the Director, the\nDirector may: (a) approve, in whole or part, the submission; (b) approve the submission on\nspecified conditions; (c) modify the submission to cure any deficiencies; (d) disapprove in whole\nor in part, the submission, directing that Respondent modify the submission, or (e) any\ncombination of the above. In the event of approval, approval upon conditions, or modification\nby the Director, Respondent must take all actions required by the submission as approved or\n\n\n\n7\nmodified by the Director. If the Director disapproves all or any portion of the submission,\nRespondent must correct all deficiencies within the time specified by the Director, and resubmit\nit for approval. If a resubmitted item is disapproved in whole or in part, the Director may again\nrequire Respondent to correct the deficiencies in accordance with the foregoing procedure, and\nthe Director may otherwise proceed to enforce the terms of this Order.\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), you must provide, along with the complete original\ndocument, a second copy of the document with those portions you believe qualify for\nconfidential treatment redacted, along with an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nIn your correspondence on this matter, please refer to “CPF No. 3-2014-5005H” and for each\ndocument you submit, please provide a copy in electronic format whenever possible. The\nactions required by this Corrective Action Order are in addition to and do not waive any\nrequirements that apply to Respondent’s pipeline system under 49 C.F.R. Part 195, under any\nother order issued to Respondent under authority of 49 U.S.C. § 60101 et seq., or under any other\nprovision of Federal 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.\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\n49 U.S.C. § 60120.\nThe terms and conditions of this Corrective Action Order are effective upon receipt.\n__________________________________ __________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety","truncated":false,"body_characters":21336}