# MARKWEST MICHIGAN PIPELINE COMPANY, L.L.C. — Warning Letter

- **operation:** document
- **citation:** CPF 320176001W
- **title:** MARKWEST MICHIGAN PIPELINE COMPANY, L.L.C. — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2017-04-14
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.446(c)(3), 195.446(j)(2).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-320176001w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-320176001w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320176001w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320176001W
**body:**

Warning Letter involving MARKWEST MICHIGAN PIPELINE COMPANY, L.L.C.. PHMSA's enforcement data identifies the cited regulations as 195.446(c)(3),  195.446(j)(2). The case was opened on 2017-04-14 and is reported as closed as of 2017-04-14. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320176001W_Warning Letter_04142017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320176001W/320176001W_Warning%20Letter_04142017.pdf

320176001W_Warning Letter_04142017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320176001W/320176001W_Warning%20Letter_04142017_text.pdf

320176001W_Warning Letter_04142017_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
April 14, 2017
MarkWest Energy Partners, L.P.
Attn: Ms. Leanne M. Meyer, P.E.
VP Environmental, Safety, Pipeline Integrity and Operations Support Services
1515 Arapahoe Street,
Tower 1, Suite 1600
Denver, CO 80202
CPF 3-2017-6001W
Dear Ms. Meyer:
On September 20-22, 2016, representatives of the Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your
MarkWest Michigan Pipeline (MarkWest) Control Room in Canonsburg, PA.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and
the probable violation(s) are:
1. §195.446 Control room management.
(c) Provide adequate information. Each operator must provide its controllers
with the information, tools, processes and procedures necessary for the
controllers to carry out the roles and responsibilities the operator has defined by
performing each of the following:
(3) Test and verify an internal communication plan to provide adequate means
for manual operation of the pipeline safely, at least once each calendar year, but
at intervals not to exceed 15 months;



MarkWest failed to test and verify the internal communication plan for manual
operation of the pipeline safely at least once each calendar year but at intervals not
exceeding 15 months. Specifically, MarkWest did not test and verify the plan in 2014
and 2015. MarkWest did test and verify the internal communication plan on 1/3/2016.
2. §195.446 Control room management.
(j) Compliance and deviations. An operator must maintain for review during
inspection:
(1) …
(2) Documentation to demonstrate that any deviation from the procedures
required by this section was necessary for the safe operation of the pipeline
facility.
MarkWest did not document the deviation from its CRM procedures. During the
review of records, it was discovered that no deviation record existed for an employee
that worked 16.5 hours. MarkWest did not include training time as time worked.
Specifically, on 9-8-16 and 9-9-16 the employee worked 16.5 hours without a
deviation report.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed
$205,638 per violation per day the violation persists up to a maximum of $2,056,380 for a
related series of violations. For violation occurring between January 4, 2012 to August 1,
2016, the maximum penalty may not exceed $200,000 per violation per day, with a maximum
penalty not to exceed $2,000,000 for a related series of violations. For violations occurring
prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per
day, with a maximum penalty not to exceed $1,000,000 for a related series of violations.
We have reviewed the circumstances and supporting documents involved in this case, and
have decided not to conduct additional enforcement action or penalty assessment proceedings
at this time. We advise you to correct the items identified in this letter. Failure to do so will
result in MarkWest being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 3-2017-6001W. 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).
2



Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
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