{"operation":"document","citation":"CPF 520080003W","title":"MARATHON OIL COMPANY — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2008-03-13","effective_on":null,"summary":"CLOSED warning letter citing 192.905(a), 192.909(a), 192.911(m)(2), 192.915(c)(2), 192.917(b), 192.921(b), 192.935(b)(1)(iv), 192.937(b), 192.945(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080003w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080003w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520080003w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520080003W","body":"Warning Letter involving MARATHON OIL COMPANY. PHMSA's enforcement data identifies the cited regulations as 192.905(a),  192.909(a),  192.911(m)(2),  192.915(c)(2),  192.917(b),  192.921(b),  192.935(b)(1)(iv),  192.937(b),  192.945(a). The case was opened on 2008-03-13 and is reported as closed as of 2008-03-13. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520080003W_warning letter_03132008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080003W/520080003W_warning%20letter_03132008.pdf\n\n520080003w_warning letter_03132008_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520080003W/520080003w_warning%20letter_03132008_text.pdf\n\n520080003w_warning letter_03132008_text.pdf\n\nSENT TO COMPLIANCE REO1SPY\nHardcopy Electronically\nII of Coptes+/Dote~&'eioE\nO\nU. S. Department\nof Transportation\nPipeline and\nHazardous Materials Safety\nAdministration\n12300 W Dakota Ave, Suite 110\nLakewood, CO 80228\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT RE UESTED\nMarch 13, 2008\nMr. Daniel F. Riemer\nManager, Marketing and Transportation\nMarathon Oil Company\n5555 San Felipe\nHouston, TX 77056\nCPF 5-200S-0003W\nDear Mr. Riemer;\nOn August 27-30, 2007, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your\nIntegrity Management Program (IMP) in Anchorage, Alaska.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation(s) are:\n$192. 905 How does an operator identify a high consequence area?\na) General. To determine which segments of an operator's transmission pipeline\nsystem are covered by this subpart, an operator must identify the high consequence\nareas. An operator must use method (1) or (2) from the definition in g 192. 903 to\nidentify a high consequence area. An operator may apply one method to its entire\npipeline system, or an operator may apply one method to individual portions of the\npipeline system.\n\n\n\nAn operator must describe in its integrity management program which method it is\napplying to each portion of the operator's pipeline system. The description must\ninclude the potential impact radius when utilized to establish a high consequence\narea. (See appendix E. I. for guidance on identifying high consequence areas. )\nla. Marathon system maps do not provide the level of detail and accuracy to\nestablish the pipeline segment locations that are located in high consequence\nareas (HCAs).\nEvidence: A, O l. c- Chugach Power Plant map — file 043035 GPB-photo. pdf,\nlb. Marathon's covered segments that impact identified sites do not include the area\nextending axially along the length of the pipeline from the outermost edge of the\nfirst potential impact circle to the outermost edge of the last contiguous potential\nimpact circle for those potential impact circles that contain an identified site.\nEvidence: A. 02. b- Chugach Power Plant map — file 043035 GPB- photo. pdf .\n1 c. Marathon's definition for identified sites provided in IMP-6-001, section 2. 1. 2 is\nnot consistent with the Integrity Management Rule. It inappropriately limits\nidentified sites to only those that are identified by public safety officials and\nLocal Emergency Planning Committees.\nEvidence: A. 03. b- HCA Segment ID, IMP-6-001, section 2. 1. 2.\n1 d. Marathon's Integrity Management Plan does not include procedural steps\nestablishing how it is determined that potential impact circles contain identified\nsites and when a potential impact circle does contain an identified site how are\nthe boundaries of the covered segment established and documented.\nEvidence: A. 04. c- Marathon Transmission Pipeline Integrity Management\nProgram, section 6-1 — 6. 1. 2, HCA Segment ID, IMP-6-001.\n$192. 921 How is the baseline assessment to be conducted?\n(b) Prioritizing segments. An operator must prioritize the covered pipeline\nsegments for the baseline assessment according to a risk analysis that considers the\npotential threats to each covered segment. The risk analysis must comply with the\nrequirements in g 192. 917.\nThe West Side Cook Inlet Gas Gathering System (CIGGS) pipeline has experienced a\nfailure due to SCC; however, an assessment method has not been selected and completed\nfor this segment that will address the potential threat of Stress Corrosion Cracking\n(SCC),\nEvidence: B. 04. e- The Baseline Assessment plan only indicates In Line (ILI) as an\nassessment technique for the West Side CIGGS segment.\n\n\n\n3. $192. 917 How does an operator identify potential threats to pipeline integrity and\nuse the threat identification in its integrity program?\n(b) Data gathering and integration. To identify and evaluate the potential threats\nto a covered pipeline segment, an operator must gather and integrate existing data\nand information on the entire pipeline that could be relevant to the covered\nsegment. In performing this data gathering and integration, an operator must\nfollow the requirements in ASME/ANSI B31. SS, section 4. At a minimum, an\noperator must gather and evaluate the set of data specified in Appendix A to\nASME/ANSI B31. SS, and consider both on the covered segment and similar non-\ncovered segments, past incident history, corrosion control records, continuing\nsurveillance records, patrolling records, maintenance history, internal inspection\nrecords and all other conditions specific to each pipeline.\nMarathon has not completed an updated data integration process that includes the results\nof completed integrity assessments and other pertinent data that has been identified since\nthe integrity assessments have been completed.\nEvidence: C. 02. b- Kenai-Nikiski Pipe Line (KNPL) system maps do not reflect data\nlearned through completion of baseline assessments which were completed in 2005.\n$192. 937 What is a continual process of evaluation and assessment to maintain a\npipeline's integrity?\n(b) Evaluation. An operator must conduct a periodic evaluation as frequently as\nneeded to assure the integrity of each covered segment. The periodic evaluation\nmust be based on a data integration and risk assessment of the entire pipeline as\nspecified in g 192. 917. For plastic transmission pipelines, the periodic evaluation is\nbased on the threat analysis specified in g 192. 917(d) For all other transmission\npipelines, the evaluation must consider the past and present integrity assessment\nresults, data integration and risk assessment information (g 192. 917), and decisions\nabout remediation (g 192. 933) and additional preventive and mitigative actions (g\n192. 935). An operator must use the results from this evaluation to identify the\nthreats specific to each covered segment and the risk represented by these threats.\nMarathon's Integrity Management Program does not specify a time&arne for the\nperformance of periodic evaluations of pipeline integrity based on data integration and\nrisk assessment as required by $192. 937(b).\nEvidence: F. 01. c- Natural Gas Transmission Pipeline Integrity Management Program,\nsections 6. 4 — 6. 4. 4.\n5. $192. 935 What additional preventive and mitigative measures must an operator\ntake?\n(b) Third party damage and outside force damage—\n\n\n\n(1) Third party damage. An operator must enhance its damage prevention\nprogram, as required under $192. 614 of this part, with respect to a covered\nsegment to prevent and minimize the consequences of a release due to third party\ndamage. Enhanced measures to an existing damage prevention program include, at\na minimum—\n(iv) Monitoring of excavations conducted on covered pipeline segments by pipeline\npersonnel. If an operator finds physical evidence of encroachment involving\nexcavation that the operator did not monitor near a covered segment, an operator\nmust either excavate the area near the encroachment or conduct an above ground\nsurvey using methods defined in NACE RP-0502-2002 (ibr, see $192. 7). An\noperator must excavate, and remediate, in accordance with ANSI/ASME B31. SS\nand $192. 933 any indication of coating holidays or discontinuity warranting direct\nexamination.\nMarathon's procedure, IMP-6-007, does not require that all un-monitored excavations be\ninvestigated for potential pipe or coating damage.\nEvidence: H. 02. a- Preventive Measures, IMP-6-007, section 2. 2. 3,\n6. $192. 935 What additional preventive and mitigative measures must an operator\ntake?\n(c) Automatic shut-off valves (ASV) or Remote control valves (RCV). If an\noperator determines, based on a risk analysis, that an ASV or RCV would be an\nefficient means of adding protection to a high consequence area in the event of a gas\nrelease, an operator must install the ASV or RCV. In making that determination,\nan operator must, at least, consider the following factors — swiftness of leak\ndetection and pipe shutdown capabilities, the type of gas being transported,\noperating pressure, the rate of potential release, pipeline profile, the potential for\nignition, and location of nearest response personnel.\nMarathon has not completed an analysis to determine if automatic shut-off valves or\nremote control valves represent an efficient means of adding protection to potentially\naffected high consequence areas.\nEvidence: H. 07. a- Marathon's Natural Gas Transmission Pipeline Integrity\nManagement Program, section 6. 3. 4. 5 and Procedure IMP-6-007, section 2. 3, — program\nhas not been implemented.\n7, $192. 945 What methods must an operator use to measure program effectiveness?\n(a) General. An operator must include in its integrity management program\nmethods to measure, on a semi-annual basis, whether the program is effective in\nassessing and evaluating the integrity of each covered pipeline segment and in\nprotecting the high consequence areas. These measures must include the four\n\n\n\noverall performance measures specified in ASME/ANSI B31. SS (ibr, see $192. 7),\nsection 9. 4, and the specific measures for each identified threat specified in\nASME/ANSI B31. SS, Appendix A, An operator must submit the four overall\nperformance measures, by electronic or other means, on a semi-annual frequency\nto OPS in accordance with $192. 951. An operator must submit its first report on\noverall performance measures by August 31, 2004. Thereafter, the performance\nmeasures must be complete through June 30 and December 31 of each year and\nmust be submitted within 2 months after those dates.\nMarathon has not measured and documented the threat-specific metrics of ASME\nB31. 8S-2004, Appendix A on a semi-annual basis. The IMP does not include\nrequirements that specify that these measures must be measured.\nEvidence: I. 01. b- Natural Gas Transmission Pipeline Integrity Management Program,\nsection 7.\n$192. 909 How can an operator change its integrity management program?\n(a) General. An operator must document any change to its program and the\nreasons for the change before implementing the change.\nMarathon's Management of Change (MOC) form for IMP program changes does not\ndesignate review and approval by the Operations Superintendent as required by the\nprocess defined in the IMP Program, section 9.\nEvidence: K, O l. a- Natural Gas Transmission Pipeline Integrity Management Program,\nsection 9.\n$192. 915 What knowledge and training must personnel have to carry out an\nintegrity management program?\n(c) Persons responsible for preventive and mitigative measures. The integrity\nmanagement program must provide criteria for the qualification of any person—\n(1) Who implements preventive and mitigative measures to carry out this subpart,\nincluding the marking and locating of buried structures; or\n(2) Who directly supervises excavation work carried out in conjunction with an\nintegrity assessment.\nMarathon's specific qualifications for key personnel that execute activities within the\nintegrity management program have not been defined by the IMP. The IMP only\nprovides general qualifications.\nEvidence: L. 02. d- Natural Gas Transmission Pipeline Integrity Management Program,\nsection 5\n\n\n\n10. $192. 911 What are the elements of an integrity management program?\n(m) A communication plan that includes the elements of ASME/ANSI B31. SS,\nsection 10, and that includes procedures for addressing safety concerns raised by—\n(1) OPS; and\n(2) A State or local pipeline safety authority when a covered segment is located in a\nState where OPS has an interstate agent agreement.\nMarathon's Integrity Management Program does not include a specific requirement that\nthe operator's risk analysis or integrity management program will be submitted to\nPHMSA or State or local pipeline safety authorities upon their request.\nEvidence; N. Ol. a- Natural Gas Transmission Pipeline Integrity Management Program,\nsection 4, 0.\nUnder 49 United States Code, $ 60122, you are subject to a civil penalty not to exceed $100, 000\nfor each violation for each day the violation persists up to a maximum of $1, 000, 000 for any\nrelated series of violations. We have reviewed the circumstances and supporting documents\ninvolved in this case, and have decided not to conduct additional enforcement action or penalty\nassessment proceedings at this time. We advise you to correct the item(s) identified in this\nletter. Failure to do so will result in Marathon Oil Company being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 5-200S-0003W. 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\nthe redacted information qualifies for confidential treatment under 5 U. S. C. 552(b).\nSincerely, ~\n/\nChri oidal\nDirector, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 Jon Strawn (¹119465)","truncated":false,"body_characters":14229}