{"operation":"document","citation":"CPF 42021006WL","title":"MARKWEST PIPELINE COMPANY, L.L.C. — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2021-02-03","effective_on":null,"summary":"CLOSED warning letter citing 195.577(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021006wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021006wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42021006wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42021006WL","body":"Warning Letter involving MARKWEST PIPELINE COMPANY, L.L.C.. PHMSA's enforcement data identifies the cited regulation as 195.577(a). The case was opened on 2021-02-03 and is reported as closed as of 2021-02-03. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42021006WL_Warning Letter_02032021_(20-171919).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021006WL/42021006WL_Warning%20Letter_02032021_(20-171919).pdf\n\n42021006WL_Warning Letter_02032021_(20-171919)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021006WL/42021006WL_Warning%20Letter_02032021_(20-171919)_text.pdf\n\n42021006WL_Warning Letter_02032021_(20-171919)_text.pdf\n\nWARNING LETTER\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nFebruary 3, 2021\nHarold E. Rinehart\nVice President G&P Health, Environment Safety & Security\nMarkwest Pipeline Company, LLC\n1515 Arapahoe Street\nTower 1, Suite 1600\nDenver, Colorado 80202\nCPF 4-2021-006-WL\nDear Mr. Rinehart:\nFrom June 8, 2020 through October 27, 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 Markwest Pipeline Company LLC’s (MarkWest) hazardous liquid transmission\npipeline near Carthage, Texas.\nOn the basis of the inspection, it is alleged that MarkWest has committed a probable violation of\nthe Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected\nand the probable violation is:\n\n\n\n2\n1. § 195.577 What must I do to alleviate interference currents?\n(a) For pipelines exposed to stray currents, you must have a program to identify, test\nfor, and minimize the detrimental effects of such currents.\nMarkWest failed to identify and test for alternating current (AC) interference as required\nby § 195.577(a) at two locations on its 6” Enterprise Y Grade line where a high voltage\nelectrical transmission line crosses the right-of-way.\nMarkWest’s written procedure SWBU-01 Section 2-Corrosion Control Rev. No. 6 Rev.\nDate 10/16/2020, subsection 8.25 states:\n“When a pipeline shares the right of way with a high voltage electrical transmission line,\neither parallel or perpendicular, AC potentials should be taken at test stations during\nthe normal monitoring cycle.”\nMarkWest failed to test for AC interference on its pipeline as required by § 195.577(a) and\nits written procedure for calendar years 2018 and 2019. AC interference checks were\nobserved in the field for the year 2020.\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related\nseries of violations. For violation occurring on or after November 27, 2018 and before July 31,\n2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum\npenalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before\nNovember 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a\nmaximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015,\nthe maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty\nnot to exceed $2,000,000 for a related series of violations. We have reviewed the circumstances\nand supporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in Markwest Pipeline Company, L.L.C.\nbeing subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2021-006-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).\n\n\n\n3\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\ncc: Anthony Minutillo, Pipeline Compliance Supervisor, MarkWest Energy Partners, LP,\ntminutillo@marathonpetroleum.com","truncated":false,"body_characters":4607}