# MARATHON OIL COMPANY — Notice of Amendment

- **operation:** document
- **citation:** CPF 520070012M
- **title:** MARATHON OIL COMPANY — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-04-09
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.465(d), 192.485(c), 192.605(b), 192.613(b), 192.615(a), 192.627, 192.709(c), 192.715, 192.745(b), 192.749.
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**body:**

Notice of Amendment involving MARATHON OIL COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.465(d),  192.485(c),  192.605(b),  192.613(b),  192.615(a),  192.627,  192.709(c),  192.715,  192.745(b),  192.749. The case was opened on 2007-04-09 and is reported as closed as of 2007-06-21. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520070012M_notice letter_04092007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070012M/520070012M_notice%20letter_04092007.pdf

520070012M_Operator Response to notice letter_ 05112007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070012M/520070012M_Operator%20Response%20to%20notice%20letter_%2005112007.pdf

520070012M_operator response to notice letter_06112007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520070012M/520070012M_operator%20response%20to%20notice%20letter_06112007.pdf

520070012M_notice letter_04092007.pdf

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12300 W. DakotaAve., Suite 110
Lakewood, CO 80228
NOTICE OF AMENDMENT
CERTIFTED MAIL - RETURN RECEIPT REOUESTED
Aoril 9.2007
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Mr. Schoffrnann
Marathon Oil Company
3201 C Street, Suite 800
Archorage, Alaska 99503
cPF 5-2007-0012M
Dear Mr. Schoffmarm:
On June 26, 2006, a representative ofthe Pipeline and Hazardous Materials Safety
Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected
Maratlon's procedures for operating natural gas pipelines in Marathon's Anchorage office.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
Marathon's plans or procedures, as described below:
1. 192.605 Procedural manual for operations maintenance and emergencies.
(b)(3) Making construction records, maps, and operating history available to
appropriate operating personnel.
Appendix 8, page I and page 4 of Marathon's Standard Operating & Maintenance
Procedures Manual, did not reflect the new 1120 psi. "set pressure" ofreliefvalve X028 at
Granite Point.
2. 192.465 External corrosion control: Monitoring.
(d) Each operator shall take prompt remedial action to correct any deficiencies
indicated by the monitoring.



3.
4.
t.
6.
Marathon's Standard Operating & Maintenance Procedures Manual, did not indicate that
prompt remedial action must be taken when deficiencies are found during corrosion control
monitoring.
192.485 Remedial measures: Transmission lines.
(c) Under paragraphs (a) and (b) ofthis section, the strength of pipe based on actual
remaining wall thickness may be determined by the procedure in ASME/ANSI B31G
or the procedure in AGA Pipeline Research Committee Project PR 3-805 (with
RSTRENG disk). Both procedures apply to corroded regions that do not penetrat€
the pipe wall, subject to the limitations prescribed in the procedures.
Marathon's Standard Operating & Maintenance Procedures Manual did not have
procedures for utilizing 831G or Rstreng to determine the remaining strength ofa pipeline.
192.613 Continuing surveillance,
(b) If a segment of pipeline is determined to be in unsatisfactory condition but no
immediate hazard exists, the operator shall initiate a program to recondition or phase
out the segment involved, or, if the segment cannot be reconditioned or phased out,
reduce the maximum allowable operating pressure in accordance with $192.619 (a)
and (b).
Marathon's Standard Operating & Maintenance Procedures Manual, did not indicate what
action must be taken if a line segment is found in unsatisfactory condition.
192.615 Emergency plans.
(a) Each operator shall establish written procedures to minimize the hazard resultins
from a gas pipeline emergency. At a minimum, the procedures must provide for the
following:
(1) Receiving, identiSing, and classifuing notices of events which require immediate
response by the operator,
(2) Establishing and maintaining adequate means of communication with
appropriate fire, police, and other public officials.
(3) Prompt and effective response to a notice of each type of emergency, including
the following:
(i) Gas detected inside or near a building.
Marathon's Standard Operating & Maintenance Procedures Manual, did not indicate what
action must be taken ifgas is detected inside or near a building.
192.627 Tapping pipeline under pressure.
Each tap made on a pipeline under pressure must be performed by a crew qualified
to make hot taps.



Marathon's Standard Operating & Maintenance Procedures Manual did not rcquire that the
crew that performs hot tapping must be qualified.
7, 192.709(c) Transrnission lines: Record keeping.
(c) A record of each patrol, survey, inspection, and test required by subparts L and
M of this part must be retained for at least 5 years or until the next patrolt survey'
inspection, or test is completed, whichever is longer.
Marathon's Standard Operating & Maintenance Procedures Manual, did not indicate that
valve inspection records must be maintained for 5 years.
8. l92.7LS Transmission line: Permanent field repair of welds,
(b) A weld may be repaired in accordance with $192.245 while the segment of
transmission line is in service if:
(1) The weld is not leaking:
(2) The pressure in the segment is reduced so that it does not produce a stress that is
more than 20 percent of the SMYS of the pipe; and
(3) Grinding of the defective area can be limited so that at least l/8-inch (3.2
millimeters) thickness in the pipe weld remains.
Marathon's Standard Operating & Maintenance Procedures Manual, did not state under
what condition a field repair of a weld could be performed.
9. 192.7 45(b\ Valve maintenance: Transmissioin lines.
(b) Each operator must take prompt remedial action to correct any valve found
inoperable, unless the operator designates an alternative valve.
Marathon's Standard Operating & Maintenance Procedures Manual, did not indicate that
prompt remedial action must be taken when an inoperable valve is found.
10. 192.7 49 Vault maintenance.
(a) Each vault housing pressure regulating and pressure limiting equipment, and
having a volumetric internal content of200 cubic feet (5.66 cubic meters) or more,
must be inspected at inter"vals not exceeding 15 months, but at least once each
calendar year, to determine that it is in good physical condition and adequately
ventilated.
(b) If gas is found in the vault, the equipment in the vault must be inspected for
leaks, and any leaks found must be repaired.
(c) The ventilating equipment must also be inspected to determine that it is
functioning properly.
(d) Each vault cover must be inspected to assure that it does not present a hazard to
public safety.
Marathon's Standard Operating & Maintenance Procedures Manual did not indicate that
vault inspections must be conducted annually.



Response to this Notice
This Notice is provided pursuant to 49 U.S.C. $ 60108(a) and 49 C.F.R. S 190.237. Enclosed
as part ofthis Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. 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 ol 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 ofwhy you believe the redacted
information qualifies for confidential treatment under 5 U.S.C. 552(b). Ifyou do not respond
within 30 days ofreceipt of this Notice, this constitutes a waiver ofyour right to contest the
allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to
find facts as alleged in this Notice without further notice to you and to issue a Final Order.
If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in
this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies
(49 C.F.R. $ 190.237). If you are not contesting this Notice, we propose that you submit your
amended procedures to my offrce within 60 days of receipt of this Notice. This period may be
extended by written request for good cause. Once the inadequacies identified herein have been
addressed in your amended procedures, this enforcement action will be closed.
In conespondence conceming this matter, please refer to CPF 5-2007-0012M and, for each
document you submit, please provide a copy in electronic format whenever possible.
Director, Westem Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operotors in Compliance Proceedings
cc: PHP-60 Compliance Registry
PHP-500 B. Flanders (#116676)
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