{"operation":"document","citation":"CPF 32025005NOA","title":"MARATHON PIPE LINE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-06-16","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(a), 195.446(c)(2), 195.446(c)(3), 195.446(c)(4), 195.446(e)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025005noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025005noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025005noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025005NOA","body":"Notice of Amendment involving MARATHON PIPE LINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.446(a),  195.446(c)(2),  195.446(c)(3),  195.446(c)(4),  195.446(e)(3). The case was opened on 2025-06-16 and is reported as closed as of 2026-01-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32025005NOA_Closure Letter_01292026_(23-264547).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025005NOA/32025005NOA_Closure%20Letter_01292026_(23-264547).pdf\n\n32025005NOA_Closure Letter_01292026_(23-264547)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025005NOA/32025005NOA_Closure%20Letter_01292026_(23-264547)_text.pdf\n\n32025005NOA_Notice of Amendment_06162025_(23-264547).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025005NOA/32025005NOA_Notice%20of%20Amendment_06162025_(23-264547).pdf\n\n32025005NOA_Notice of Amendment_06162025_(23-264547)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025005NOA/32025005NOA_Notice%20of%20Amendment_06162025_(23-264547)_text.pdf\n\n32025005NOA_Operator Response to Notice_09182025_(23-264547).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025005NOA/32025005NOA_Operator%20Response%20to%20Notice_09182025_(23-264547).pdf\n\n32025005NOA_Closure Letter_01292026_(23-264547)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nVIA ELECTRONIC MAIL TO: rjstamour@marathonpetroleum.com;\ncaleach@marathonpetroleum.com; migray@marathonpetroleum.com\n901 Locust Street, Suite 480\nKansas City, MO 64106\nJanuary 29, 2026\nMr. Richard St Amour\nMarathon Pipe Line, LLC\n539 South Main Street\nFindlay, OH 45840\nRE: CPF 3-2025-005-NOA\nDear Mr. St Amour:\nFrom April 17 to May 17, 2023, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), conducted and inspection of Marathon Pipe Line, LLC’s (Marathon)\nprocedures and records in Findlay, Ohio. On June 16, 2025, pursuant to 49 CFR § 190.206,\nPHMSA issued a Notice of Amendment which proposed amendment of Marathon’s procedures.\nMarathon submitted its amended procedures on September 18 and December 5, 2025, and January\n28, 2026. PHMSA has reviewed the amended procedures, and it appears that the inadequacies\noutlined in the Notice of Amendment have been corrected.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Carlie Leach, Compliance Specialist, Marathon Pipe Line\ncaleach@marathonpetroleum.com\nMichael J. Gray, Environmental Safety Security Compliance Director, Marathon\nPipeline, migray@marathonpetroleum.com\n\n32025005NOA_Notice of Amendment_06162025_(23-264547)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: rjstamour@marathonpetroleum.com,\njerader@marathonpetroleum.com; Migray@marathonpetroleum.com\nJune 16, 2025\nMr. Richard St Amour\nMarathon Pipe Line, LLC\n539 South Main Street\nFindlay, OH 45840\nCPF 3-2025-005-NOA\nDear Mr. St Amour:\nFrom April 17 to May 17, 2023, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49\nUnited States Code (U.S.C.), inspected, remotely and on-site, Marathon Pipe Line, LLC’s\n(Marathon) procedures and records in Findlay, Ohio.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nMarathon’s plans or procedures. The items inspected, alleged inadequacies, and proposed\nrevisions are described below:\n1. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements of\nthis section….\n(c) Provide adequate information. Each operator must provide its controllers with the\ninformation, tools, processes and procedures necessary for the controllers to carry\nout the roles and responsibilities the operator has defined by performing each of the\nfollowing:\n(1) . . . .\n(2) Conduct a point-to-point verification between SCADA displays and related field\nequipment when field equipment is added or moved and when other changes that\naffect pipeline safety are made to field equipment or SCADA displays;\n\n\n\nMarathon’s procedure, “MPL-OPR-01598-PRS” (August 25, 2021, amend. June 30, 2023),\ncross-referenced in its “MPL Pipeline Operations Center Control Room Management Plan”\n(August 25, 2022, amend. October 05, 2023) (CRM Plan) section 6.4, was not adequate to\ndescribe the requirements for thorough documentation of point-to-point (P2P) verification per §\n195.446(c)(2).\n“MPL-OPR-01598-PRS” failed to include instructions for the verification and documentation of\nthe values and states between the SCADA system and field end device. It also failed to include a\nrequirement for these conditions to match. “MPL-OPR-01598-PRS” provided an example of\nverification in section 5.2, “End to End Verification,” that stated, “[c]ompare the readings on a\npressure transmitter in the field to the readings of the SCADA display.” Prior to this, section 5.2\nnoted, “[t]he tolerance of field displays and data communication latency should be taken into\nconsideration when comparing end device displays to SCADA.” This language suggested the\ninformation between the end device and SCADA can be different and that result would be\nconsidered acceptable to Marathon. Thus, section 5.2 allowed Marathon’s controllers to accept\npotentially inaccurate information, which could cause a controller to have to perform their roles\nand responsibilities of operating the pipeline safely without the best information.\nPHMSA reviewed Marathon’s P2P records for Robinson Rio 81 and identified that several\nelements, including adequate description, were missing from the verification documentation,\nwhich was required to be recorded pursuant to “MPL-OPR-01598-PRS.” For example,\nMarathon did not document (1) the details of which displays were verified, (2) the actual status\nor value observed in the field and SCADA (the same response was documented for analog, set\npoint and control points), or (3) the exact same date and time was documented for all 5 points.\nThus, Marathon failed to (1) provide adequate instruction to its controllers to conduct P2P\nverification between SCADA displays and related field equipment and (2) maintain appropriate\ndocumentation of P2P verification to determine compliance, per the requirements of\n§§ 195.446(c)(2), (j)(2).\nMarathon must formalize its procedures to provide a thorough P2P verification that includes\ninstructions to support consistency and ensure records are maintained to demonstrate all the\nelements verified pursuant to § 195.446(j)(2).\n2. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements of\nthis section. . . .\n(c) Provide adequate information. Each operator must provide its controllers with the\ninformation, tools, processes and procedures necessary for the controllers to carry\nout the roles and responsibilities the operator has defined by performing each of the\nfollowing:\n1 Robinson Rio 8 is a Marathon pipeline facility monitored and controlled from the control room.\n\n\n\n(1) . . . .\n(3) Test and verify an internal communication plan to provide adequate means for\nmanual operation of the pipeline safely, at least once each calendar year, but at\nintervals not to exceed 15 months;\nMarathon’s CRM Plan detailing its internal communication plan was not adequate to\ndemonstrate compliance with § 195.446(c)(3). Specifically, Marathon’s “Internal\nCommunication Plan for Manual Operation” did not provide adequate means for manual\noperation of the pipeline safety, nor did it require adequate documentation of its tests of its\ninternal communication plan at the regulatory timeframe to demonstrate compliance.\nDuring the inspection, Marathon stated its policy was to not move product manually through the\npipeline system once it manually shuts down the pipeline systems in the event of a SCADA loss.\nSection 7 of the CRM Plan referenced sections 3.4 and 12.1 of Marathon’s “Operations &\nLogistics Business Continuity Plan” (July 10, 2023) (O&LBCP), which described the\nresponsibilities of the controllers during a SCADA failure; however, that description did not\nmatch what was provided in the CRM Procedures. O&LBCP sections 3.4 and 12.1 did not\ninclude detail of what was expected of the controllers during manual operation. Marathon\nmentioned, during the inspection, that it has its pipeline systems listed to track what has been\nshut down, but this was not required in either the CRM Plan or O&LBCP. Marathon also did not\ndefine who it was that updated this list as systems are communicated as being shut down. The\nO&LBCP did not address who oversaw reporting field data, the frequency of these reports, or\nwhere this information should be recorded for pipeline systems that are still operating. Even\nwhen product is not flowing, the pipeline is still considered in operation, and Marathon is still\nrequired to patrol and have leak detection in place during the shutdown. Both the CRM Plan and\nO&LBCP failed to include requirements to report and document abnormal operating conditions,\nemergencies, and leaks.\nMarathon did complete tests of its “Internal Communication Plan for Manual Operation” of the\npipeline systems for the years 2020, 2021 and 2022. However, Marathon did not maintain\nrecords that were adequate to demonstrate compliance with its procedures or § 195.446(c)(3). In\n2020 and 2021, Marathon’s records demonstrate that it only completed a portion of the plan by\nmaking the \"send word now\" notification calls and asking employees to review their roles. This\nwas not an adequate demonstration that a full test of Marathon’s Internal Communication Plan\nfor Manual Operation was completed.\nIn 2022, Marathon only conducted a tabletop exercise which was not adequate to demonstrate\ncompliance with § 195.446(c)(3). Per Marathon’s records, the tabletop exercise had a mix of\nindividuals representing different work groups in the session. The session utilized the\nquestion/answer process to review procedures. A pre-populated list, by console, was provided to\nsupport the drill and identified which systems were currently running to know which systems\nneeded to be shut down. The tabletop exercise did not cover calling in to the control room to\nmanually document field conditions during the shutdown. The control function went to field\npersonnel, which is cause for concern considering the control room personnel are the subject\nmatter experts on managing the system holistically. Not engaging the control room to manage\nshut down status and monitor for leaks through patrolling and pressure monitoring is a failure of\n\n\n\nthe testing process. Thus, Marathon’s CRM Plan did not provide adequate means for manual\noperation of the pipeline safely, nor did it require adequate documentation of its tests of its\ninternal communication plan at the regulatory timeframe to demonstrate compliance with\n§ 195.446(c)(3).\nMarathon must develop an internal communication plan for the safe manual operation of the\npipeline and a procedure to test the plan once each calendar year, not to exceed 15 months. The\nplan must include verification that the pipeline systems have been shut down, accommodations\nfor leak detection while the line is in the operating status of shutdown, identification of key\noperating points that will be monitored and methods to report and document field conditions.\n3. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements of\nthis section. . . .\n(c) Provide adequate information. Each operator must provide its controllers with\nthe information, tools, processes and procedures necessary for the controllers to\ncarry out the roles and responsibilities the operator has defined by performing each\nof the following:\n(1) . . . .\n(4) Test any backup SCADA systems at least once each calendar year, but at\nintervals not to exceed 15 months; and\nMarathon’s CRM Plan section 8 for testing any backup SCADA systems was inadequate because\n(1) it did not require enough detail to demonstrate compliance, (2) the tests did not include a test\nof the backup system, and (3) the procedures were not formalized nor subject to review. As a\nresult, Marathon failed to maintain records adequate to demonstrate that it complied with the\nregulatory timeframe for testing its backup SCADA system at least once each calendar year, not\nto exceed 15 months, per the requirements of § 195.446(c)(4).\nPHMSA reviewed Marathon’s records for its monthly failover of the SCADA servers. Some of\nthe records only included the dates but not the initials of the person who conducted or verified\nthe test. These records included visits to the “hardened area”2 of the control room. These\nrecords were created by the SCADA Team, rather than by the control room, so there was no test\nof the backup system provided. It is important to document which employee(s) did the work as\nwell as the date the work was completed. The SCADA Team developed procedures for these\ntests, but those procedures were not formalized or controlled. These procedures were only\nmaintained on One Note. Because these procedures were essential for maintaining the SCADA\nsystem and related to compliance, they need to be formalized, controlled, and subject to review.\n2 “Hardened area” of the control room is Marathon’s term describing an area structurally enhanced to be used to\nsupport controllers and control room operations during severe weather.\n\n\n\nMarathon conducted a test of Blufton in fall 2020, spring 2021, and fall 2021. However,\nMarathon did not provide any documentation, other than shift schedules, for these tests\nconducted in 2020 and 2021. Shift schedules are inadequate to provide adequate detail\ndocumenting the test to demonstrate compliance with the requirements of § 195.446(c)(4).\nMarathon conducted tests in 2022, between April 6 and April 13. Marathon documented the test\nthrough a survey completed by the controller who participated in the test. While the survey\nasked for responses to certain questions, it did not provide enough detail of what was tested to\ndemonstrate that an adequate test was completed. For example, the survey did not include (1)\nwhat commands were sent, (2) which alarms were acknowledged, (3) whether printers were\nworking, (4) whether IT business computers were working, (5) whether monitors were working,\n(6) whether all comms were working, etc. The CRM Plan, section 8.4, required,\n“documentation\nof the BPOC activation [to] be recorded using the POC Backup Activation Checklist and\nmaintained by the POC performing the BPOC.” Thus, Marathon’s procedures were inadequate\nto demonstrate that tests of backup SCADA systems were conducted adequately and within the\nregulatory timeframe specified in § 195.446(c)(4).\nMarathon must formalize its procedures used to perform the monthly failover test and\ndocumentation. It must also develop procedures to test the backup SCADA system, including\nthe functioning backup center, server, and all equipment that makes up the back up control\ncenter. The amended procedure must require documentation of the test, including, but not\nlimited to, identifying the functioning server during the test, start and end time, controller(s) on\nduty, alarm/event function, phones, command functions, etc.\n4. § 195.446 Control room management.\n(a) General. This section applies to each operator of a pipeline facility with a\ncontroller working in a control room who monitors and controls all or part of a\npipeline facility through a SCADA system. Each operator must have and follow\nwritten control room management procedures that implement the requirements of\nthis section. . . .\n(e) Alarm management. Each operator using a SCADA system must have a written\nalarm management plan to provide for effective controller response to alarms. An\noperator's plan must include provisions to:\n(1) . . . .\n(3) Verify the correct safety-related alarm set-point values and alarm descriptions\nwhen associated field instruments are calibrated or changed and at least once each\ncalendar year, but at intervals not to exceed 15 months;\nMarathon’s “Alarm Management Plan” (May 2, 2023) (ALMP) and its CRM Plan were not\nsufficiently detailed to adequately verify the correct safety-related alarm set-point values and\nalarm descriptions at least once each calendar year, but at intervals not to exceed 15 months, per\n§ 195.446(e)(3). As a result of its inadequate procedures, Marathon did not provide records to\ndemonstrate they verified all safety related alarms each calendar year not to exceed 15 months\nfor the years 2020, 2021, and 2022.\n\n\n\nSections 13.4 of the CRM Plan, 22.2, and 22.5 of Marathon’s ALMP provided that, “Safety\nRelated alarm setpoint values and alarm descriptions (SCADA names) must be verified at least\nonce each calendar year, but at intervals not to exceed 15 months.” Section 22.5 of the ALMP\nstated “Work Orders are assigned for Safety Related alarms that need to be tested and verified\nand to each field location where those alarms exist.” Marathon indicated to PHMSA during the\ninspection that Work Orders are created for all alarms, whether the alarm requires field testing or\nnot. Marathon relied on the field work order activity and field process to demonstrate\ncompliance. Marathon provided two procedures to demonstrate the process of set point\nverification: Major Pressure Relief valve DOT inspection Task List (Task List) and MPL –\nPressure Control Device DOT Compliance (MPL MNT-00966-PRS). Step 3 of the Inspection\nProcedures section of the Task List directed the field technician to “[n]otify the OC (Operations\nCenter) to ‘Off Scan’ the device being inspected.” Taking the point off scan in SCADA system\nwill result in no alarm being received in the control room from the field PLC. MPL MNT-00966-\nPRS section 4.1, “Roles and Responsibilities for the Technician,” stated, “[a]t the end of the\ninspection of the pressure monitoring devices, [the technician must confirm] with the POC or\nMPC equivalent the correct receipt of the data points by the POC.” There is conflict between\nthese two documents that undermined determination of compliance. The execution of Step 3\nrenders the information required for in section 4.1 unobtainable. While individual alarm\nverifications were presented for inspection, Marathon did not provide a record that confirmed all\npoints had been verified each calendar year not to exceed 15 months. Marathon did indicate to\nPHMSA, following the inspection, that it did monitor alarm verifications monthly through\nadministrative reports, however, no such reports were provided for inspection. Additionally, the\nprocess defined through Marathon’s procedure did not verify the correct safety related alarm\ndescription, as required by § 195.446(e)(3).\nMarathon also has a CPM Leak Detection system that generates alarms which are passed to\nSCADA in digital format to present to the controller. The alarm set point is not static, rather it is\ndynamic and is based on complex algorithms and coefficients. Marathon personnel indicated\nthey review the false alarms frequently and adjust coefficients to support improved leak\ndetection alarming accuracy. These are safety related alarms, as acknowledged by Marathon and\nhave not been part of the work order process for all other alarms described in the process above.\nThus, Marathon did not provide a record that it verified the all safety-related alarm set-point\nvalues and alarm descriptions were correct when associated field instruments were calibrated or\nchanged and at least once each calendar year, but at intervals not to exceed 15 months, per the\nrequirements of § 195.446(e)(3).\nMarathon must amend its “Alarm Management Plan” (May 2, 2023) (ALMP) and its CRM Plan\nin detail to verify the correct safety-related alarm set-point values and alarm descriptions at least\nonce each calendar year, but at intervals not to exceed 15 months, per § 195.446(e)(3).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings.\n\n\n\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under\n5 U.S.C. § 552(b), along with the complete original document you must provide a second copy\nof the document with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment\nunder 5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in\nthis Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not\ncontesting this Notice, we propose that you submit your amended procedures to my office within\n30 days of receipt of this Notice. This period may be extended by written request for good\ncause. Once the inadequacies identified herein have been addressed in your amended\nprocedures, this enforcement action will be closed.\nIt is requested (not mandated) that Marathon maintain documentation of the safety improvement\ncosts associated with fulfilling this Notice of Amendment (preparation/revision of plans,\nprocedures) and submit the total to Gregory A. Ochs, Director, Central Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please\nrefer to CPF 3-2025-005-NOA and, for each document you submit, please provide a copy in\nelectronic format whenever possible.\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Jennifer Rader, Advanced Compliance Professional, jerader@marathonpetroleum.com\nMichael J. Gray, Environmental Safety Security Compliance Director,\nMiGray@marathonpetroleum.com\nEnclosures: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":23669}