# BUCKEYE PARTNERS, LP — Warning Letter

- **operation:** document
- **citation:** CPF 120165001W
- **title:** BUCKEYE PARTNERS, LP — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2016-04-20
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.573(a)(1).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-120165001w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/120165001W
**body:**

Warning Letter involving BUCKEYE PARTNERS, LP. PHMSA's enforcement data identifies the cited regulation as 195.573(a)(1). The case was opened on 2016-04-20 and is reported as closed as of 2016-04-20. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

120165001W_Warning Letter_04202016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120165001W/120165001W_Warning%20Letter_04202016.pdf

120165001W_Warning Letter_04202016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120165001W/120165001W_Warning%20Letter_04202016_text.pdf

120165001W_Warning Letter_04202016_text.pdf

WARNING LETTER
OVERNIGHT EXPRESS DELIVERY
April 20, 2016
T. Scott Collier
VP, Performance Assurance & Asset Integrity
Buckeye Partners, L.P.
Five TEK Park
9999 Hamilton Boulevard
Breinigsville, PA 18031
CPF 1-2016-5001W
Dear Mr. Collier:
From April 13 through 17, 2015, a representative of the Pipeline and Hazardous Materials Safety
Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Buckeye
Partners, L.P.’s (Buckeye) corrosion control records for Inspection Unit #4723 – Decatur (Phillips), in
Breinigsville, PA.
As a result of the inspection, it appears that you have committed a probable violation of the Pipeline
Safety Regulations, Title 49, Code of Federal Regulations. This probable violation is a repeat violation.
The items inspected and the probable violation is:
1. §195.573 What must I do to monitor external corrosion control?
(a) Protected pipelines. You must do the following to determine whether cathodic
protection required by this subpart complies with Sec. 195.571:
(1) Conduct tests on the protected pipeline at least once each calendar year, but with
intervals not exceeding 15 months. However, if tests at those intervals are impractical
for separately protected short sections of bare or ineffectively coated pipelines, testing
may be done at least once every 3 calendar years, but with intervals not exceeding 39
months.
Buckeye failed to conduct tests on protected pipelines at least once each calendar year, with intervals not
exceeding 15 months.
During the inspection, the PHMSA inspector reviewed procedures and records related to monitoring
external corrosion on protected pipelines. Buckeye’s procedure A-02: External Corrosion Control, issued
12/12, states in Section 3 (Cathodic Protection Survey Procedures and Processes) that “Trained and
qualified field personnel conduct the surveys at intervals in accordance with the Comprehensive
Scheduling Chart – Regulatory Inspections (See 195 O and M Manual Section F-34, Ex. A).” The



1-2016-5001W
Comprehensive Scheduling Chart (F-34 Ex. A) states that pipe-to-soil and pipe-to-casing readings are to
be performed at least 1 time per calendar year and not to exceed 15 months.
The PHMSA inspector reviewed the CP Survey Reports for mainline pipelines in Buckeye’s
Responsibility Area #383 for 2012, 2013, and 2014.
The records show that at 69 locations, pipe-to-soil readings took place on 3/5/2013 and 6/19/2014 (58 of
these are located in an HCA, 11 are not in an HCA). These exceeded the 15 month maximum by 14 days.
The records also show that at 5 locations, pipe-to-soil readings took place on 3/11/2013 and 6/19/2014 (4
of these are located in an HCA, 1 is not in an HCA). These exceeded the 15 month maximum by 8 days.
Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per
violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations.
For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per
violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations. We
have reviewed the circumstances and supporting documents involved in this case, and have decided not to
conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to
correct the item identified in this letter. Failure to do so will result in Buckeye being subject to additional
enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 1-
2016-5001W. 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).
Sincerely,
Byron Coy, P.E.
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
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