# MARATHON PIPE LINE LLC — Notice of Amendment

- **operation:** document
- **citation:** CPF 520100002M
- **title:** MARATHON PIPE LINE LLC — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2010-01-04
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.475(a), 192.715(b), 192.743(a).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520100002M
**body:**

Notice of Amendment involving MARATHON PIPE LINE LLC. PHMSA's enforcement data identifies the cited regulations as 192.475(a),  192.715(b),  192.743(a). The case was opened on 2010-01-04 and is reported as closed as of 2010-04-23. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520100002M_notice of amendment_01042010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100002M/520100002M_notice%20of%20amendment_01042010.pdf

520100002M_notice of amendment_01042010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100002M/520100002M_notice%20of%20amendment_01042010_text.pdf

520100002M_operator response_03042010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520100002M/520100002M_operator%20response_03042010.pdf

520100002M_notice of amendment_01042010_text.pdf

NOTICE 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.



During 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.
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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 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)
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