# MARATHON PIPE LINE LLC — Warning Letter

- **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:** Not available
- **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.

Official case documents:

32021047WL_Warning Letter_10072021_(20-172195).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021047WL/32021047WL_Warning%20Letter_10072021_(20-172195).pdf

32021047WL_Warning Letter_10072021_(20-172195)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32021047WL/32021047WL_Warning%20Letter_10072021_(20-172195)_text.pdf

32021047WL_Warning Letter_10072021_(20-172195)_text.pdf

WARNING LETTER
VIA ELECTRONIC MAIL TO: smlyon@marathonpetroleum.com, jchunt@mplx.com and
mlbailey@marathonpetroleum.com
October 7, 2021
Shawn M. Lyon
President
Marathon Pipe Line LLC
539 South Main Street
Findlay, OH 45840
CPF 3-2021-047-WL
Dear Mr. Lyon:
From April 29, 2020, through November 12, 2020, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
(U.S.C.) inspected procedures, facilities, and records relevant to your Marathon Pipe Line LLC
(MPL) products system in Illinois, Michigan, Indiana and Ohio.
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 (CFR). The items inspected
and the probable violations are:
1. § 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 annual inspections performed in 2017 and 2018 on the relief device TPRV-3-5 (on Lima Tank
20-3) could not verify that the relief device was functioning properly, in good mechanical



condition, and was adequate from the standpoint of capacity and reliability of operation for the
service in which it was used.
The testing of the relief device TPRV-3-5 (on Lima Tank 20-3) on August 13, 2017 was not
completed as indicated in the email response provided to PHMSA on December 01, 2020. The
next annual DOT inspection was scheduled for October 04, 2018 but still was not completed. No
further DOT testing was performed in 2018. Relief device TPRV-3-5 passed the annual DOT
inspection conducted on September 11, 2019.
2. § 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 inspections of the Lima Maumee Relief 01 RV1 located on the Harpster-Lima system and the
HVL relief valve RV1 (V78) located on the Robinson-Lima system were inadequate to
demonstrate that the relief valves are functioning properly in 2020 as intended since the “as left”
setpoints of the relief devices were set incorrectly and the “pressure relief” setpoints were
misinterpreted.
The review of the inspection records indicates that the “calculated as left nitrogen setpoint” for the
Lima Maumee Relief 01 RV1 was miscalculated by the technician who performed the first testing
on June 16, 2020 and the re-testing on July 27, 2020 following PHMSA’s inquiry. Although the
miscalculated as left setpoint values from both tests were lower than the actual pressure relief
setpoint, the pressure relief setpoint value was not properly identified nor used in the determination
of the as left setpoints above.
On the Robinson Lima HVL relief valve RV1 (V78), the review of the inspection records indicated
that the “calculated as left nitrogen setpoint” was miscalculated by another technician who
performed the testing on June 23, 2020. Although the miscalculated as left setpoint value from the
test was lower than the actual pressure relief setpoint, the pressure relief setpoint value was not
properly identified nor used in the determination of the as left setpoint above.
After conducting an operator qualification evaluation, it was determined that the two technicians,
who performed the above inspections, needed to be re-qualified on the task which occurred on
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October 21, 2020. Also, MPL revised its inspection form to prevent confusion with the pressure
relief set-point.
3. §195.573 What must I do to monitor external corrosion control?
(a)….
(c) Rectifiers and other devices. You must electrically check for proper performance
each device in the first column at the frequency stated in the second column.
Device Check frequency
Other interference
At least once each calendar year, but with intervals not exceeding 15
bond
months.
Non-critical bonds located on the Wabash and Robinson - Lima 10" Products systems were not
electrically checked each calendar year, but with intervals not exceeding 15 months for proper
performance.
Specifically, four non-critical bonds on the Wabash system and one non-critical bond on the
Robinson - Lima 10" Products system were not inspected in 2018 at the following locations:
 (WAB 12" ROBINSON ANAPOLIS BV'S 0+07 - 664+21 WAB-20-RM-A & MPs 9+29
/19+82 / 25+12 / 33+91)
 (ROL 10" WABASH STATION - ANAPOLIS BV'S 0+01-664+331, ROL-01-RN-A &
MP 9+85)
MPL indicated that the above bonds were not checked due to the lack of facility access. However,
missed checks (exceptions) of non-critical interference bonds should have been tracked and
addressed in a manner that complies with the regulatory requirement of § 195.573(c).
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed
$222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related
series of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021,
the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to
a maximum of $2,186,465 for a related series of violations. For violation occurring on or after
November 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per
violation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on
or after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed
$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022.
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
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time. We advise you to correct the item(s) identified in this letter. Failure to do so will result in
Marathon Pipe Line LLC 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 3-2021-047-WL. 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).
Sincerely,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: John Hunt, Vice President Operations, jchunt@mplx.com,
Mandy L Bailey, Regulatory Compliance Coordinator, mlbailey@marathonpetroleum.com
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