{"operation":"document","citation":"CPF 32021047WL","title":"MARATHON PIPE LINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-10-07","effective_on":null,"summary":"CLOSED warning letter citing 195.428(a), 195.573(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021047wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021047wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32021047wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32021047WL","body":"Warning Letter involving MARATHON PIPE LINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.428(a),  195.573(c). The case was opened on 2021-10-07 and is reported as closed as of 2021-10-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32021047WL_Warning Letter_10072021_(20-172195).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021047WL/32021047WL_Warning%20Letter_10072021_(20-172195).pdf\n\n32021047WL_Warning Letter_10072021_(20-172195)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021047WL/32021047WL_Warning%20Letter_10072021_(20-172195)_text.pdf\n\n32021047WL_Warning Letter_10072021_(20-172195)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: smlyon@marathonpetroleum.com, jchunt@mplx.com and\nmlbailey@marathonpetroleum.com\nOctober 7, 2021\nShawn M. Lyon\nPresident\nMarathon Pipe Line LLC\n539 South Main Street\nFindlay, OH 45840\nCPF 3-2021-047-WL\nDear Mr. Lyon:\nFrom April 29, 2020, through November 12, 2020, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected procedures, facilities, and records relevant to your Marathon Pipe Line LLC\n(MPL) products system in Illinois, Michigan, Indiana and Ohio.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 195.428 Overpressure safety devices and overfill protection systems\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the case\nof pipelines used to carry highly volatile liquids, at intervals not to exceed 7½ months,\nbut at least twice each calendar year, inspect and test each pressure limiting device,\nrelief valve, pressure regulator, or other item of pressure control equipment to\ndetermine that it is functioning properly, is in good mechanical condition, and is\nadequate from the standpoint of capacity and reliability of operation for the service\nin which it is used.\nThe annual inspections performed in 2017 and 2018 on the relief device TPRV-3-5 (on Lima Tank\n20-3) could not verify that the relief device was functioning properly, in good mechanical\n\n\n\ncondition, and was adequate from the standpoint of capacity and reliability of operation for the\nservice in which it was used.\nThe testing of the relief device TPRV-3-5 (on Lima Tank 20-3) on August 13, 2017 was not\ncompleted as indicated in the email response provided to PHMSA on December 01, 2020. The\nnext annual DOT inspection was scheduled for October 04, 2018 but still was not completed. No\nfurther DOT testing was performed in 2018. Relief device TPRV-3-5 passed the annual DOT\ninspection conducted on September 11, 2019.\n2. § 195.428 Overpressure safety devices and overfill protection systems\n(a) Except as provided in paragraph (b) of this section, each operator shall, at\nintervals not exceeding 15 months, but at least once each calendar year, or in the case\nof pipelines used to carry highly volatile liquids, at intervals not to exceed 7½ months,\nbut at least twice each calendar year, inspect and test each pressure limiting device,\nrelief valve, pressure regulator, or other item of pressure control equipment to\ndetermine that it is functioning properly, is in good mechanical condition, and is\nadequate from the standpoint of capacity and reliability of operation for the service\nin which it is used.\nThe inspections of the Lima Maumee Relief 01 RV1 located on the Harpster-Lima system and the\nHVL relief valve RV1 (V78) located on the Robinson-Lima system were inadequate to\ndemonstrate that the relief valves are functioning properly in 2020 as intended since the “as left”\nsetpoints of the relief devices were set incorrectly and the “pressure relief” setpoints were\nmisinterpreted.\nThe review of the inspection records indicates that the “calculated as left nitrogen setpoint” for the\nLima Maumee Relief 01 RV1 was miscalculated by the technician who performed the first testing\non June 16, 2020 and the re-testing on July 27, 2020 following PHMSA’s inquiry. Although the\nmiscalculated as left setpoint values from both tests were lower than the actual pressure relief\nsetpoint, the pressure relief setpoint value was not properly identified nor used in the determination\nof the as left setpoints above.\nOn the Robinson Lima HVL relief valve RV1 (V78), the review of the inspection records indicated\nthat the “calculated as left nitrogen setpoint” was miscalculated by another technician who\nperformed the testing on June 23, 2020. Although the miscalculated as left setpoint value from the\ntest was lower than the actual pressure relief setpoint, the pressure relief setpoint value was not\nproperly identified nor used in the determination of the as left setpoint above.\nAfter conducting an operator qualification evaluation, it was determined that the two technicians,\nwho performed the above inspections, needed to be re-qualified on the task which occurred on\n2\n\n\n\nOctober 21, 2020. Also, MPL revised its inspection form to prevent confusion with the pressure\nrelief set-point.\n3. §195.573 What must I do to monitor external corrosion control?\n(a)….\n(c) Rectifiers and other devices. You must electrically check for proper performance\neach device in the first column at the frequency stated in the second column.\nDevice Check frequency\nOther interference\nAt least once each calendar year, but with intervals not exceeding 15\nbond\nmonths.\nNon-critical bonds located on the Wabash and Robinson - Lima 10\" Products systems were not\nelectrically checked each calendar year, but with intervals not exceeding 15 months for proper\nperformance.\nSpecifically, four non-critical bonds on the Wabash system and one non-critical bond on the\nRobinson - Lima 10\" Products system were not inspected in 2018 at the following locations:\n (WAB 12\" ROBINSON ANAPOLIS BV'S 0+07 - 664+21 WAB-20-RM-A & MPs 9+29\n/19+82 / 25+12 / 33+91)\n (ROL 10\" WABASH STATION - ANAPOLIS BV'S 0+01-664+331, ROL-01-RN-A &\nMP 9+85)\nMPL indicated that the above bonds were not checked due to the lack of facility access. However,\nmissed checks (exceptions) of non-critical interference bonds should have been tracked and\naddressed in a manner that complies with the regulatory requirement of § 195.573(c).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related\nseries of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021,\nthe maximum penalty may not exceed $218,647 per violation per day the violation persists, up to\na maximum of $2,186,465 for a related series of violations. For violation occurring on or after\nNovember 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per\nviolation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on\nor after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed\n$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case, and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\n3\n\n\n\ntime. We advise you to correct the item(s) identified in this letter. Failure to do so will result in\nMarathon Pipe Line LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2021-047-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nGregory A. Ochs\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: John Hunt, Vice President Operations, jchunt@mplx.com,\nMandy L Bailey, Regulatory Compliance Coordinator, mlbailey@marathonpetroleum.com\n4","truncated":false,"body_characters":8658}