{"operation":"document","citation":"CPF 32023032WL","title":"MARATHON PIPE LINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2023-11-20","effective_on":null,"summary":"CLOSED warning letter citing 195.579(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32023032wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32023032wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32023032wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32023032WL","body":"Warning Letter involving MARATHON PIPE LINE LLC. PHMSA's enforcement data identifies the cited regulation as 195.579(c). The case was opened on 2023-11-20 and is reported as closed as of 2023-11-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32023032WL_Warning Letter_11202023_(23-264993).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023032WL/32023032WL_Warning%20Letter_11202023_(23-264993).pdf\n\n32023032WL_Warning Letter_11202023_(23-264993)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32023032WL/32023032WL_Warning%20Letter_11202023_(23-264993)_text.pdf\n\n32023032WL_Warning Letter_11202023_(23-264993)_text.pdf\n\nWARNING LETTER\nVIA ELECTRONIC MAIL TO: rjstamour@marathonpetroleum.com;\nmlbailey@marathonpetroleum.com\nNovember 20, 2023\nRichard St. Amour\nPresident\nMarathon Pipe Line LLC\n539 South Main St\nFindlay, OH 45840\nCPF 3-2023-032-WL\nDear Mr. St. Amour:\nFrom April 3 through September 1, 2023, 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 Marathon Pipe Line LLC’s (Marathon) OWC inspection system. The\nheadquarters inspection was completed in Findlay, Ohio and the field inspection ran from\nOwensboro, Kentucky to Catlettsburg, Kentucky.\nAs a result of the inspection, it is alleged that Marathon has committed a probable violation of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item\ninspected and the probable violation is:\n1. § 195.579 What must I do to mitigate internal corrosion?\n(a) . . . .\n(c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect the\ninternal surface of the pipe for evidence of corrosion. If you find internal corrosion\nrequiring corrective action under § 195.585, you must investigate circumferentially\nand longitudinally beyond the removed pipe (by visual examination, indirect\nmethod, or both) to determine whether additional corrosion requiring remedial\naction exists in the vicinity of the removed pipe.\n\n\n\nMarathon failed to inspect the internal surface of pipe for evidence of corrosion. During\nthe headquarters inspection conducted in Findley, Ohio from April 3-7, 2023, while\nreviewing corrosion records it was noted that an internal corrosion inspection was not\ncompleted during a project that removed pipe from the pipeline. An internal inspection is\nrequired anytime pipe is removed from the pipeline.\nProject 158525 replaced tank lines for tank 801 and 802 at Lebanon Junction Station.\nThe Land and Pipe Inspection Checklist report was filled out on August 10, 2021. This\nreport records corrosion issues such as coating damage and external corrosion when a\npipeline is exposed and internal corrosion whenever a pipe is removed from the pipeline.\nAlthough a portion of the pipeline was removed, during this project an internal inspection\nwas not completed.\nPer a response from Marathon on October 17, 2023, the project leader and inspector did\nnot believe that an internal inspection was required because the pipeline had previously\nbeen drained and abandoned in place. The project team did not consider removal of\nexisting above-grade piping at the tie-in with new piping at a flanged valve. Marathon\ntook actions to ensure an internal inspection would be completed on similar projects by\nupdating the form and completing training with all company project leaders.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a\nrelated series of violations. For violation occurring on or after March 21, 2022 and before\nJanuary 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,142 for a related series of violations. For violation\noccurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021 and before\nMay 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations. For violation occurring on or after November 27, 2018 and before\nJuly 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a\nmaximum penalty not to exceed $2,132,679. For violation occurring on or after November 2,\n2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per\nviolation 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\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.\n\n\n\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 3-2023-032-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\nthe redacted 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: Mandy Bailey, DOT Compliance Assistant, Marathon Pipeline, LLC\n(mlbailey@marathonpetroleum.com)","truncated":false,"body_characters":6274}