# BUCKEYE PARTNERS, LP — Notice of Amendment

**Citation:** CPF 12026051NOA  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2026-05-04

CLOSED notice of amendment citing 195.440(a), 195.440(g).

## Document text

Notice of Amendment involving BUCKEYE PARTNERS, LP. PHMSA's enforcement data identifies the cited regulations as 195.440(a),  195.440(g). The case was opened on 2026-05-04 and is reported as closed as of 2026-06-26. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12026051NOA_Closure Letter_06262026_(25-332203).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026051NOA/12026051NOA_Closure%20Letter_06262026_(25-332203).pdf

12026051NOA_Closure Letter_06262026_(25-332203)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026051NOA/12026051NOA_Closure%20Letter_06262026_(25-332203)_text.pdf

12026051NOA_Notice of Amendment_05042026_(25-332203).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026051NOA/12026051NOA_Notice%20of%20Amendment_05042026_(25-332203).pdf

12026051NOA_Notice of Amendment_05042026_(25-332203)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026051NOA/12026051NOA_Notice%20of%20Amendment_05042026_(25-332203)_text.pdf

12026051NOA_Operator Response to Notice_05292026_(25-332203).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026051NOA/12026051NOA_Operator%20Response%20to%20Notice_05292026_(25-332203).pdf

12026051NOA_Closure Letter_06262026_(25-332203)_text.pdf

U.S. Department
of Transportation
Pipeline and
Hazardous Materials
Safety Administration
840 Bear Tavern Road, Suite 300
West Trenton, New Jersey 08628
609.771.7800
VIA EMAIL TO: trusso@buckeye.com
June 26, 2026
Todd Russo
President and Chief Executive Officer
Buckeye Partners, LP
4200 Westheimer Road #975
Houston, Texas 77027
RE: CPF 1-2026-051-NOA
Dear Mr. Russo:
From March 17 through November 13, 2025, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), Eastern Region,
pursuant to Chapter 601 of Title 49 United States Code (U.S.C.), conducted an integrated
inspection of Buckeye Partners, LP’s (Buckeye) plans and procedures for maintenance and normal
operations in Allentown, Pennsylvania. As a result of the inspection, PHMSA issued a Notice of
Amendment on May 4, 2026, which proposed amendments to Buckeye’s procedures.
Buckeye submitted its amended procedures on May 29, 2026. My staff reviewed the amended
procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been
corrected.
This letter is to inform you no further action is necessary and this case is now closed. Thank you
for your cooperation.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
cc: Mark Copeland, Manager, Pipeline Safety & DOT Compliance, mcopeland@buckeye.com
Robert Osika, Director, DOT Compliance, rosika@buckeye.com@buckeye.com

12026051NOA_Notice of Amendment_05042026_(25-332203)_text.pdf

U.S. Department
of Transportati on
Pipeline and
Hazardous Materials
Safety Administration
840 Bear Tavern Road, Suite 300
West Trenton, New Jersey 08628
609.771.7800
NOTICE OF AMENDMENT
VIA EMAIL TO: trusso@buckeye.com
May 4, 2026
Todd Russo
President and Chief Executive Officer
Buckeye Partners, LP
4200 Westheimer Road #975
Houston, Texas 77027
CPF 1-2026-051-NOA
Dear Mr. Russo:
From March 17 through November 13, 2025, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), Eastern Region,
pursuant to Chapter 601 of Title 49 United States Code (U.S.C.), conducted an integrated
inspection of Buckeye Partners, LP’s (Buckeye) plans and procedures for maintenance and normal
operations in Allentown, Pennsylvania.
As a result of the inspection, Eastern Region has identified an inadequacy found within Buckeye’s
plans or procedures. The alleged inadequacy and proposed revision is described below:
1. § 195.440 Public awareness.
(a) Each pipeline operator must develop and implement a written
continuing public education program that follows the guidance
provided in the American Petroleum Institute's (API) Recommended
Practice (RP) 1162 (incorporated by reference, see § 195.3).
(b) …
(g) The program must be conducted in English and in other
languages commonly understood by a significant number and



CPF 1-2026-051-NOA
concentration of the non-English speaking population in the operator’s
area.
Buckeye’s written public awareness procedural manual was inadequate to ensure safe operation of
a pipeline facility. Specifically, Buckeye’s Public Awareness Manual, Section F - Message Type
and Content, Revision 11 (04/18/25) (Public Awareness Manual), failed to provide sufficient
details regarding its processes to ensure compliance with the requirements of section 195.440(g).
The table of contents of the Public Awareness Manual cited section 4 as the section covering the
procedure for addressing message type and content. However, section 4 was identified as not
applicable within the document.
Section 1.4.2 in the Public Awareness Manual, regarding message content for each audience group,
only identified Spanish as commonly used by a significant concentration of the non-English
speaking population, and noted that Buckeye has developed certain materials in Spanish in
addition to English. However, the manual failed to provide details regarding how to address areas
where languages other than Spanish are commonly understood by a significant number and
concentration of the non-English speaking population along the pipeline.
In addition, the Public Awareness Manual failed to include a procedure to determine the number
and concentration of the non-English speaking population in the operator’s area. The information
in Exhibit A in the manual lacked detail as to which languages, other than English or Spanish, are
most spoken, particularly for certain counties including Boone, IN, where a significant portion of
the non-English speaking population speaks a language that is different than Spanish.
Therefore, Buckeye’s written public awareness procedural manual was inadequate to ensure safe
operation of a pipeline facility. Eastern Region proposes that Buckeye revise its procedures to
address the above deficiency.
Response to this Notice
This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement
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).
Following the receipt of this Notice, you have 30 days to submit written comments, revised
procedures, or a request for a hearing under § 190.211. 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
Page 2 of 3



CPF 1-2026-051-NOA
without further notice to you and to issue an Order Directing Amendment. If 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 CFR § 190.206). If you are not contesting this
Notice, we propose that you submit your amended procedures to my office within 30 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.
It is requested (not mandated) that Buckeye maintain documentation of the safety improvement
costs associated with fulfilling this Notice of Amendment (preparation/revision of plans,
procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and
Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer
to CPF 1-2026-051-NOA and, for each document you submit, please provide a copy in electronic
format whenever possible.
Sincerely,
Robert Burrough
Director, Eastern Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
cc: Mark Copeland, Manager, Pipeline Safety & DOT Compliance,
mcopeland@buckeye.com
Robert Osika, Director, DOT Compliance, rosika@buckeye.com@buckeye.com
Page 3 of 3

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/12026051NOA>
- Source ID: `phmsa-enforcement`
- SHA-256: `7df6e5f98c4cb96f3f4475986fb728dd2151c658b20d3e3fd6fef1714c9cfc42`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-23T05:28:33.510Z
- Document slug: `phmsa-enforcement-12026051noa`

### Source metadata

```json
{
  "cpf": "12026051NOA",
  "operator": "BUCKEYE PARTNERS, LP",
  "region": "Eastern",
  "pipelineType": "INTRASTATE LIQUID",
  "caseStatus": "CLOSED",
  "citedSections": [
    "195.440(a)",
    "195.440(g)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 5,
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  ],
  "extractedAgencyDocumentCount": 2,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "BUCKEYE PARTNERS, LP"
}
```
