{"operation":"document","citation":"CPF 32025013NOA","title":"MARATHON PIPE LINE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2025-05-20","effective_on":null,"summary":"CLOSED notice of amendment citing 195.401(b)(3), 195.402(c)(13), 195.414(d)(4), 195.414(d)(5), 195.414(d)(6), 195.420(b), 195.452(h)(1)(ii).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025013noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025013noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-32025013noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/32025013NOA","body":"Notice of Amendment involving MARATHON PIPE LINE LLC. PHMSA's enforcement data identifies the cited regulations as 195.401(b)(3),  195.402(c)(13),  195.414(d)(4),  195.414(d)(5),  195.414(d)(6),  195.420(b),  195.452(h)(1)(ii). The case was opened on 2025-05-20 and is reported as closed as of 2026-01-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n32025013NOA_Closure Letter_01072026_(24-299107).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025013NOA/32025013NOA_Closure%20Letter_01072026_(24-299107).pdf\n\n32025013NOA_Closure Letter_01072026_(24-299107)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025013NOA/32025013NOA_Closure%20Letter_01072026_(24-299107)_text.pdf\n\n32025013NOA_Notice of Amendment_05202025_(24-299107).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025013NOA/32025013NOA_Notice%20of%20Amendment_05202025_(24-299107).pdf\n\n32025013NOA_Notice of Amendment_05202025_(24-299107)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025013NOA/32025013NOA_Notice%20of%20Amendment_05202025_(24-299107)_text.pdf\n\n32025013NOA_Operator Response to Notice_08012025_(24-299107).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32025013NOA/32025013NOA_Operator%20Response%20to%20Notice_08012025_(24-299107).pdf\n\n32025013NOA_Closure Letter_01072026_(24-299107)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety Administration\n901 Locust Street, Suite 480\nKansas City, MO 64106\nVIA ELECTRONIC MAIL TO: rjstamour@marathonpetroleum.com;\nmigray@marathonpetroleum.com;\nJanuary 7, 2026\nMr. Rich St. Amour\nPresident\nMarathon Pipe Line LLC\n539 South Main Street\nFindlay, OH 45840\nRE: CPF 3-2025-013 NOA\nDear Mr. St. Amour:\nFrom March 18 to March 22 and April 8 to April 11, 2024, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), conducted an onsite inspection of the plans and procedures for integrity\nmanagement and operations and maintenance of Marathon Pipe Line, LLC (“Marathon”) in\nFindlay, Ohio. On May 20, 2025, PHMSA issued a Notice of Amendment (Notice) letter for the\ncase number referenced above. The Notice cited Marathon for inadequacies found within its plans\nor procedures.\nMarathon submitted its amended procedures on August 1, 2025. PHMSA reviewed the amended\nprocedures, and it appears that the inadequacies outlined in Items 1, 2, 3 and 5 of the Notice have\nbeen corrected. This letter is to inform you that PHMSA hereby withdraws Item 4 of the Notice.\nThe other Items are now closed.\nSincerely,\nDavid Barrett\nActing Director, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\ncc: Michael J. Gray, migray@marathonpetroleum.com\n\n32025013NOA_Notice of Amendment_05202025_(24-299107)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: rjstamour@marathonpetroleum.com;\nmigray@marathonpetroleum.com; mlbailey@marathonpetroleum.com\nMay 20, 2025\nMr. Rich St. Amour\nPresident\nMarathon Pipe Line LLC\n539 South Main Street\nFindlay, OH 45840\nCPF 3-2025-013 NOA\nDear Mr. St. Amour:\nFrom March 18 to March 22 and April 8 to April 11, 2024, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United\nStates Code (U.S.C.), conducted an onsite inspection of the plans and procedures for integrity\nmanagement and operations and maintenance of Marathon Pipe Line LCC (“Marathon”) in\nFindlay, Ohio.\nAs a result of the inspection, PHMSA has identified the apparent inadequacies found within\nMarathon’s plans or procedures. The items inspected and the inadequacies are described below:\n1. § 195.401 General requirements.\n(a) . . .\n(b) An operator must make repairs on its pipeline system according to the following\nrequirements:\n(1) . . .\n(3) Prioritizing repairs. An operator must consider the risk to people, property, and\nthe environment in prioritizing the correction of any conditions referenced in\nparagraphs (b)(1) and (2) of this section.\nMarathon’s procedures were inadequate for prioritizing repairs on its pipeline system.\nSpecifically, during the headquarters inspection, PHMSA reviewed Marathon procedures,\n“MPL-MNT-00504-PRS Responding to Anomalies” and “MPL-MNT-00807 Data Analysis of\nan In-Line Inspection (ILI) Survey.” These procedures did not describe how the risk to people,\nproperty, and the environment would be considered when prioritizing the correction of\n\n\n\nconditions, as required by § 195.401(b)(3). Therefore, Marathon’s procedures did not adequately\naddress the requirements of § 195.401(b)(3) and PHMSA proposes Marathon’s procedures must\nbe amended to provide guidance on prioritizing repairs based on risk to people, property, and the\nenvironment.\n2. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) . . .\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(1) . . .\n(13) Periodically reviewing the work done by operator personnel to determine the\neffectiveness of the procedures used in normal operation and maintenance and\ntaking corrective action where deficiencies are found.\nMarathon’s procedure “MPL-DOT-00027-PRS, Review for Effectiveness,” did not provide\nadequate guidance to conduct reviews of work done by operator personnel to determine the\neffectiveness of Operations and Maintenance Procedures (O&M), per the requirements of\n§ 195.402(c)(13). Specifically, the procedure did not include the frequencies for the periodic\nreviews and did not contain specificity to ensure that an effectiveness review of all O&M\nprocedures required by Part 195 – Subpart F were done. Furthermore, the procedure provided no\nguidance to the Advisor (Marathon’s term for the reviewer) on what is required to determine\nprocedure effectiveness. The procedure simply stated that the Advisor will have the procedure in\nhand to review for effectiveness. Therefore, PHMSA proposes Marathon must amend its\nprocedure to meet the requirements of § 195.402(c)(13).\n3. § 195.414 Inspections of pipelines in areas affected by extreme weather and natural\ndisasters.\n(a) . . .\n(d) Remedial action. An operator must take prompt and appropriate remedial action\nto ensure the safe operation of a pipeline based on the information obtained as a\nresult of performing the inspection required under paragraph (a) of this section.\nSuch actions might include, but are not limited to:\n(1). . .\n(4) Performing additional patrols, surveys, tests, or inspections;\n(5) Implementing emergency response activities with Federal, State, or local\npersonnel; and\n(6) Notifying affected communities of the steps that can be taken to ensure public\nsafety.\nMarathon’s procedure for responding to pipelines affected by extreme weather and natural\ndisasters did not provide enough guidance to personnel to take prompt and appropriate remedial\naction to ensure the safe operation of a pipeline, per the requirements of § 195.414(d).\nSpecifically, PHMSA reviewed Marathon’s “LS-Extreme Weather and Natural Disaster\nGuidelines,” which is used to respond to the affected areas. Section 12.1, “DOT Jurisdictional\nAsset Considerations,” merely restated § 195.414(d). For §§ 195.414(d)(4) through (6)—\n\n\n\nperforming additional surveys, implementing emergency response activities, and notifying\naffected communities of steps that can be taken to ensure public safety, respectively—there was\nno detail or reference to other procedures on how to carry out these activities. Therefore,\nPHMSA proposes Marathon must amend the procedure to provide additional details for meeting\nthe requirements of § 195.414(d).\n4. §195.420 Valve maintenance.\n(a) . . .\n(b) Each operator must, at least twice each calendar year, but at intervals not\nexceeding 7 1/2 months, inspect each mainline valve to determine that it is\nfunctioning properly. Each rupture-mitigation valve (RMV), as defined in § 195.2\nand not contained in a gathering line, or alternative equivalent technology that is\ninstalled under § 195.258(c) or § 195.418, must also be partially operated.\nOperators are not required to close the valve fully during the inspection; a\nminimum 25 percent valve closure is sufficient to demonstrate compliance, unless\nthe operator has operational information that requires an additional closure\npercentage for maintaining reliability.\nMarathon’s written procedure did not address the requirement for inspecting all check valves1\nthat have been determined by Marathon to be a mainline valve for proper functioning, per the\nrequirements of § 195.402(b). Section 4 of Marathon’s procedure for inspecting mainline valves,\n“MPL - Valve DOT Compliance Maintenance and Inspection (MPL-DOT-00862-PRS),”\nreferred to a “Mainline Valve Inspection Task List.” Under Section 3.2.5.1 of the Task List,\nMarathon addressed what to do for a check valve. However, the Task List was written\nspecifically for those check valves that have the capability to manually operate the clapper.2 The\nprocedure did not address valves that are accessible above ground and do not have a manually\noperated clapper, nor did it address check valves that are below ground. As such, the check\nvalves would only receive a visual inspection if above-ground. If below-ground, the valves\nwould only see a check for leaks and security at the valve site. No check for proper operation\nwas required per the Task List. Therefore, PHMSA proposes Marathon must amend the Task\nList in accordance with § 195.402(a) to meet the requirements of § 192.420(b) for all mainline\ncheck valves.\n5. § 195.452 Pipeline integrity management in high consequence areas.\n(a) . . .\n(h) What actions must an operator take to address integrity issues? —\n(1) General requirements. An operator must take prompt action to address all\nanomalous conditions in the pipeline that the operator discovers through the\nintegrity assessment or information analysis. In addressing all conditions, an\noperator must evaluate all anomalous conditions and remediate those that could\nreduce a pipeline's integrity, as required by this part. An operator must be able to\ndemonstrate that the remediation of the condition will ensure that the condition is\n1 A check valve is a valve that closes to prevent backward flow of liquid. Marathon utilizes these valves on one side\nof a large body of water to prevent backflow of product should a rupture occur in the large body of water.\n2 The “clapper” is the component within a check valve that prevents the backflow of product. It is mounted within\nthe valve on a hinge and blocks the flow of product if the product reverses flow.\n\n\n\nunlikely to pose a threat to the long-term integrity of the pipeline. An operator must\ncomply with all other applicable requirements in this part in remediating a\ncondition. Each operator must, in repairing its pipeline systems, ensure that the\nrepairs are made in a safe and timely manner and are made so as to prevent damage\nto persons, property, or the environment. The calculation method(s) used for\nanomaly evaluation must be applicable for the range of relevant threats.\n(i) . . .\n(ii) Long-term pressure reduction. When a pressure reduction exceeds 365 days, the\noperator must notify PHMSA in accordance with paragraph (m) of this section and\nexplain the reasons for the delay. An operator must also take further remedial\naction to ensure the safety of the pipeline.\nMarathon’s procedure was inadequate for recognizing when pressure reductions become long-\nterm and require PHMSA notification, per the requirements of § 195.452(h)(1)(ii). Specifically,\nMarathon’s Integrity Management Program (IMP) procedure, section 2.7.2.3, “Long-term\npressure Reduction,” did not specify who reviews pressure changes, how pressure changes are\ntracked or when they are tracked, nor did it provide a mechanism for determining when pressure\nreductions have exceeded 365 days. Additionally, the procedure did not specify who will\nprovide the required notifications to PHMSA, in accordance with § 195.452(m). Therefore,\nPHMSA proposes Marathon’s procedure must be revised to adequately address the requirements\nof § 195.452(h)(1)(ii).\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.\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 5\nU.S.C. § 552(b), along with the complete original document you must provide a second copy of\nthe 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\n\n\n\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 3-2025-013 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: Michael J. Gray, migray@marathonpetroleum.com\nMandy L. Bailey, mlbailey@marathonpetroleum.com\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings","truncated":false,"body_characters":14936}