# MARKWEST PIPELINE COMPANY, L.L.C. — Warning Letter

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

Official case documents:

42021006WL_Warning Letter_02032021_(20-171919).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021006WL/42021006WL_Warning%20Letter_02032021_(20-171919).pdf

42021006WL_Warning Letter_02032021_(20-171919)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42021006WL/42021006WL_Warning%20Letter_02032021_(20-171919)_text.pdf

42021006WL_Warning Letter_02032021_(20-171919)_text.pdf

WARNING LETTER
ELECTRONIC MAIL - RETURN RECEIPT REQUESTED
February 3, 2021
Harold E. Rinehart
Vice President G&P Health, Environment Safety & Security
Markwest Pipeline Company, LLC
1515 Arapahoe Street
Tower 1, Suite 1600
Denver, Colorado 80202
CPF 4-2021-006-WL
Dear Mr. Rinehart:
From June 8, 2020 through October 27, 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 Markwest Pipeline Company LLC’s (MarkWest) hazardous liquid transmission
pipeline near Carthage, Texas.
On the basis of the inspection, it is alleged that MarkWest has committed a probable violation of
the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected
and the probable violation is:



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1. § 195.577 What must I do to alleviate interference currents?
(a) For pipelines exposed to stray currents, you must have a program to identify, test
for, and minimize the detrimental effects of such currents.
MarkWest failed to identify and test for alternating current (AC) interference as required
by § 195.577(a) at two locations on its 6” Enterprise Y Grade line where a high voltage
electrical transmission line crosses the right-of-way.
MarkWest’s written procedure SWBU-01 Section 2-Corrosion Control Rev. No. 6 Rev.
Date 10/16/2020, subsection 8.25 states:
“When a pipeline shares the right of way with a high voltage electrical transmission line,
either parallel or perpendicular, AC potentials should be taken at test stations during
the normal monitoring cycle.”
MarkWest failed to test for AC interference on its pipeline as required by § 195.577(a) and
its written procedure for calendar years 2018 and 2019. AC interference checks were
observed in the field for the year 2020.
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to 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. For violations occurring prior to November 2, 2015,
the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty
not to exceed $2,000,000 for a related series of violations. 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 time. We advise you to correct the
item(s) identified in this letter. Failure to do so will result in Markwest Pipeline Company, L.L.C.
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 4-2021-006-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).



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Sincerely,
Mary L. McDaniel, P.E.
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
cc: Anthony Minutillo, Pipeline Compliance Supervisor, MarkWest Energy Partners, LP,
tminutillo@marathonpetroleum.com
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