MARATHON PIPE LINE LLC — Notice of Amendment

party submissionOfficial PDF520100002M_operator response_03042010.pdf#

520100002M_notice of amendment_01042010_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED January 4, 2010 Mr. John Swearingen President Marathon Pipe Line LCC 539 S. Main Street Findlay, OH 45840 CPF 5-2010-0002M Dear Mr. Swearingen: On August 17 and 21, 2009, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Marathon Pipe Line LLC’s (Marathon) Operation and Maintenance procedures in Kenai, Alaska. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within Marathon’s plans or procedures, as described below: 1. §192.475 Internal corrosion control: General. (a) Corrosive gas may not be transported by pipeline, unless the corrosive effect of the gas on the pipeline has been investigated and steps have been taken to minimize internal corrosion. Marathon’s procedures for internal corrosion are inadequate because they do not specify the methods used by Marathon for determining the corrosive properties of the transported gas.#

520100002M_notice of amendment_01042010_text.pdf, page 2During the inspection Marathon indicated that it investigates the corrosive properties of the transported gas and provided the following internal corrosion control procedures: 1) Standard Number MPLMNT072, Internal Corrosion Management, Revision 1, dated 2/23/09; and 2) Standard Number MPLMNT020, Corrosion Management – Regulatory Compliance, Revision 10, dated 6/04/09. However, these procedures do not specify the methods used by Marathon for determining the corrosive properties of the transported gas. 2. §192.715 Transmission lines: Permanent field repair of welds. Each weld that is unacceptable under §192.241(c) must be repaired as follows: (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 Marathon’s procedures for repair of in-service weld defects are inadequate because they do not include the prescribed requirements §192.715(b)(1) and (2). Marathon provided Standard Number MPLMNT030, In-Service Welding, Revision Number 2, dated 12/15/06 as their in- service welding procedures. These procedures allow repair of in-service weld defects; however, they do not include the prescribed requirements of §192.715(b)(1) and (2). 3. §192.743 Pressure limiting and regulating stations: Capacity of relief devices (a) Pressure relief devices at pressure limiting stations and pressure regulating stations must have sufficient capacity to protect the facilities to which they are connected. Except as provided in §192.739(b), the capacity must be consistent with the pressure limits of §192.201(a). This capacity must be determined at intervals not exceeding 15 months, but at least once each calendar year, by testing the devices in place or by review and calculations. Marathon failed to provide procedures which require the capacity of the relief devices be determined at intervals not exceeding 15 months, but at least once each calendar year. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as part of this 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 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). If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your 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. 2#

520100002M_notice of amendment_01042010_text.pdf, page 3If, 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 office within 45 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 correspondence concerning this matter, please refer to CPF 5-2010-0002M and send all responses to my attention at 222 W. 7th Ave. #200, PO Box 37, Anchorage, Alaska 99513. For each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Dennis Hinnah Deputy Director, Western Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings cc: PHP-60 Compliance Registry PHP-500 T. Johnson (#123867) 3#