{"operation":"document","citation":"CPF 520100001W","title":"MARATHON PIPE LINE LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2010-01-04","effective_on":null,"summary":"CLOSED warning letter citing 192.179(b)(1), 192.241(c), 192.703(b), 192.739(a), 192.739(a)(4), 192.743(a), 192.745(a).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100001w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100001w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-520100001w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/520100001W","body":"Warning Letter involving MARATHON PIPE LINE LLC. PHMSA's enforcement data identifies the cited regulations as 192.179(b)(1),  192.241(c),  192.703(b),  192.739(a),  192.739(a)(4),  192.743(a),  192.745(a). The case was opened on 2010-01-04 and is reported as closed as of 2010-01-04. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n520100001W_warning letter_01042010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100001W/520100001W_warning%20letter_01042010.pdf\n\n520100001W_warning letter_01042010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100001W/520100001W_warning%20letter_01042010_text.pdf\n\n520100001W_warning letter_01042010_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 4, 2010\nMr. John Swearingen\nPresident\nMarathon Pipe Line LLC\n539 S. Main Street\nFindlay, OH 45840\nCPF 5-2010-0001W\nDear Mr. Swearingen:\nBetween August 17 and 20, 2009, representatives of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected\nMarathon Pipe Line LLC’s (Marathon) records and facilities in Kenai, 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\nthe probable violations are:\n1. §192.103 General.\nPipe must be designed with sufficient wall thickness, or must be installed with\nadequate protection, to withstand anticipated external pressures and loads that will\nbe imposed on the pipe after installation.\n\n\n\n§192.703 General.\n(b) Each segment of pipeline that becomes unsafe must be replaced, repaired, or\nremoved from service.\nMarathon failed to protect its two 10-inch diameter pipelines from subsea scour and washouts\nat the shoreline on the West side of the Cook Inlet. The two 10-inch CIGGS marine pipelines\nare exposed at the shoreline and seabed scouring, washouts, rocks, sand and other debris has\ndestroyed the concrete outer coating and the inner HDPE coating. The pipeline has been\nscoured to bare metal and the metal is pitted.\n2. §192.179 Transmission line valves.\n(b) Each sectionalizing block valve on a transmission line, other than offshore\nsegments, must comply with the following:\n(1) The valve and the operating device to open or close the valve must be readily\naccessible and protected from tampering and damage.\nMarathon failed to protect its mainline valve at the Aurora facility on the West side of Cook\nInlet from tampering and damage. The mainline lateral valve on the CIGGS at the Aurora\nfacility was neither locked or fenced or otherwise protected from tampering or damage.\n3. §192.241 Inspection and test of welds\n(c) The acceptability of a weld that is nondestructively tested or visually inspected is\ndetermined according to the standards in Section 9 of API Standard 1104\n(incorporated by reference, see §192.7). However, if a girth weld is unacceptable\nunder those standards for a reason other than a crack, and if Appendix A to API\n1104 applies to the weld, the acceptability of the weld may be further determined\nunder that appendix.\nThe acceptability of nondestructively tested welds associated with the “Marathon COP\nInterconnect Piping Project” were determined according to ASME B31.3 and not determined\naccording to Section 9 of API Standard 1104. Marathon provided a weld map and various\nnondestructive testing reports for welds which indicate that the nondestructive testing results\nwere evaluated to ASME B31.3 standards.\n4. §192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and Pressure\nregulating station and its equipment must be subjected at intervals not exceeding 15\nmonths, but at least once each calendar year, to inspections and tests to determine\nthat it is–\n(4) Properly installed and protected from dirt, liquids, or other conditions that might\nprevent proper operation.\nPHMSA personnel observed that the relief valve discharge piping configuration, associated\n2\n\n\n\nwith several relief valves, would not prevent the accumulation of water, ice, or snow that\nmight prevent proper operation of the relief device. Flapper style rain caps were not in the\nclosed position or there were no rain caps at all.\n5. §192.739 Pressure limiting and regulating stations: Inspection and testing.\n(a) Each pressure limiting station, relief device (except rupture discs), and Pressure\nregulating station and its equipment must be subjected at intervals not exceeding 15\nmonths, but at least once each calendar year, to inspections and tests to determine\nthat it is–\n(1) In good mechanical condition;\n(2) Adequate from the standpoint of capacity and reliability of operation for the\nservice in which it is employed;\n(3) Except as provided in paragraph (b) of this section, set to control or relieve at the\ncorrect pressure consistent with the pressure limits of §192.201(a); and\nMarathon failed to inspect and test its pressure relief device (PSV) at the Starisky production\npad on the KKPL pipeline at intervals not exceeding 15 months, but at least once each\ncalendar year. Although, Marathon confirmed that this valve protects the pipeline that runs\nfrom the Starisky production pad to the KKPL pipeline from overpressure. Marathon could not\nprovide records to demonstrate that this pressure relief device has ever been maintained,\naccording to §192.703. In addition, Marathon did not have this PSV listed in their O&M\nmanual, nor is the PSV valve identified on their P&ID schematic.\n6. §192.743 Pressure limiting and regulating stations: Capacity of relief devices\n(a) Pressure relief devices at pressure limiting stations and pressure regulating\nstations must have sufficient capacity to protect the facilities to which they are\nconnected. Except as provided in §192.739(b), the capacity must be consistent with\nthe pressure limits of §192.201(a). This capacity must be determined at intervals not\nexceeding 15 months, but at least once each calendar year, by testing the devices in\nplace or by review and calculations.\nThe operator failed to provide evidence that the capacity of the relief devices had been\ndetermined at intervals not exceeding 15 months, but at least once each calendar year.\n7. §192.745 Valve maintenance: Transmission lines.\n(a) Each transmission line valve that might be required during any emergency must\nbe inspected and partially operated at intervals not exceeding 15 months, but at least\nonce each calendar year.\nMarathon failed to inspect and test its mainline valve at the Starisky production pad at\nintervals not exceeding 15 months, but at least once each calendar year. Although, Marathon\nconfirmed that this valve is the mainline isolation valve for the pipeline that runs from the\nStarisky production pad to the KKPL pipeline, Marathon could not provide records to\ndemonstrate that this mainline valve has ever been maintained, according to §192.745. In\n3\n\n\n\naddition, Marathon did not have this mainline isolation valve listed in their O&M manual, nor\nis the mainline valve identified on their P&ID schematic.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed\n$100,000 for each violation for each day the violation persists up to a maximum of $1,000,000\nfor any related series of violations. We have reviewed the circumstances and supporting\ndocuments involved in this case, and have decided not to conduct additional enforcement\naction or penalty assessment proceedings at this time. We advise you to correct the item(s)\nidentified in this letter. Failure to do so will result in Marathon Pipe Line LLC being subject\nto additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer\nto CPF 5-2010-0001W and send all responses to my attention at 222 W. 7th Ave. #200, PO\nBox 37, Anchorage, Alaska 99513. Be advised that all material you submit in response to this\nenforcement action is subject to being made publicly available. If you believe that any portion\nof your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along\nwith the complete original document you must provide a second copy of the document with\nthe portions you believe qualify for confidential treatment redacted and an explanation of why\nyou believe the redacted information qualifies for confidential treatment under 5 U.S.C.\n552(b).\nSincerely,\nDennis Hinnah\nDeputy Director, Western Region\nPipeline and Hazardous Materials Safety Administration\ncc: PHP-60 Compliance Registry\nPHP-500 J. Strawn (#123982)\n4","truncated":false,"body_characters":8718}