WEST SHORE PIPELINE CO — Notice of Probable Violation

party submissionOfficial PDF120165004_Operator Response to Notice_07182016.pdf#

120165004_NOPV PCP PCO_06202016_text.pdf, page 1Official PDFNOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER OVERNIGHT EXPRESS DELIVERY June 20, 2016 T. Scott Collier VP, Performance Assurance & Asset Integrity West Shore Pipeline Co. Five TEK Park 9999 Hamilton Boulevard Breinigsville, PA 18031 CPF 1-2016-5004 Dear Mr. Collier: From May 19, 2014 through July 31, 2015, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code, inspected Buckeye Partners, L.P.’s procedures and records for the West Shore Pipeline Company (Buckeye West Shore) in Breinigsville, PA. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violations are: 1. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. Buckeye West Shore failed to follow its procedures for monitoring electrical isolation at casings along its pipeline system.#

120165004_NOPV PCP PCO_06202016_text.pdf, page 21-2016-5004 Buckeye West Shore’s Corrosion Manual procedure A-02 External Corrosion Control, versions 12/2012, 09/2012, and 12/2011, and procedure J-02 External Corrosion Control version 09/2010, Section 9.4 states: “Annually during the corrosion control survey, installed electrical isolation devices shall be inspected for proper operation.” The PHMSA inspector reviewed Buckeye West Shore’s External Corrosion records for Line Segment EB252US-US254GT. The records indicate that Buckeye West Shore failed to inspect electrical isolation devices for proper isolation at 6 locations. In an email dated July 31, 2015, Buckeye West Shore provided additional details on the missed readings: 1. 2. At the first 5 locations noted in the table below, casing vents and test leads did not exist until 2012, leading to the missed readings in 2011 and 2012. Readings were taken in 2013 at these 5 locations. At MP 131.890, the 2013 Casing P/S reading was missed due to failure to acquire lane closures for safe access to the test point. Location MP Date Carrier Pipe P/S (V) Casing P/S (V) 125.790 2011 NR NR 2012 NR NR 6/27/13 -1.337 -0.745 127.250 2011 NR NR 2012 NR NR 6/27/13 -1.593 -0.947 130.300 2011 NR. NR 2012 NR NR 6/27/13 -1.399 -0.703 130.800 2011 NR NR 2012 NR NR 6/27/13 -1.417 -0.766 131.250 2011 NR. NR 2012 NR NR 6/27/13 -1.356 -0.711 131.890 5/23/11 -1.160 -1.086 5/25/12 -1.237 -0.736 2013 -1.312 NR 2. §195.575 Which facilities must I electrically isolate and what inspections, tests, and safeguards are required? (c) You must inspect and electrically test each electrical isolation to assure the isolation is adequate. Buckeye West Shore failed to inspect and electrically test each electrical isolation at two casings along its pipeline system to assure the isolation is adequate. Buckeye’s Corrosion Manual procedure A-05 Shorted Casing, issued 6/2013, 12/2011, and procedure J-05 Shorted Casing, issued 9/2010, Section 2.7 of each procedure states in part: 120165004_NOPV_PCP_PCO_06202016 Page 2 of 6#

120165004_NOPV PCP PCO_06202016_text.pdf, page 31-2016-5004 “The following procedures and evaluations determine whether or not a shorted condition exists, and if the condition detrimentally affects the level of pipeline cathodic protection. . . [that when comparing the potentials of the pipeline and its casing] if the potential difference is 100 millivolts or less, a shorted condition may exist”. Section 1.5 of each procedure states in part that: “Casings that are determined to be directly (metallically) shorted as a result of the testing described in this policy shall be cause to initiate a corrective action plan for remediation. This plan shall be initiated within six months of the evaluation by the Lead Corrosion Engineer. . . ” The PHMSA inspector reviewed Buckeye West Shore’s External Corrosion records for Line Segment EB252US-US254GT. The records indicated that there were two locations (five instances) in which the potential difference between the pipe-to-soil readings on the casing and carrier pipes was less than 100 millivolts. In an email dated July 31, 2015, PHMSA asked Buckeye West Shore to provide additional information for the two locations. Buckeye West Shore responded as follows: Location 39.880: “This casing was tested using the Panhandle Eastern test method in 2010 (WO 640030) and found to be shorted. The casing is being monitored by ILI and last inspected in 2013. There has been no growth of external features within the casing and maximum pit depth is less than 15%. The pipeline displays adequate cathodic protection at this crossing.” Location 48.280: “This casing was tested using the Panhandle Eastern test method in 2008 and found to be shorted. The casing is being monitored by ILI and last inspected in 2013. No external corrosion features have been identified in this casing. The pipeline displays adequate cathodic protection at this crossing.” Monitoring the casings with ILI in lieu of repairing the shorted casing fails to meet the intent of §195.575(c). Location MP Date Carrier Pipe P/S (V) Casing P/S (V) Δ (mv.) Days since confirming short 39.880 6/27/11 -1.183 -1.181 2 5/22/12 -1.328 -1.325 3 6/10/13 -1.361 -1.364 3 715 48.280 6/28/11 -1.217 -1.214 3 5/30/12 -1.342 -1.332 10 7/2/13 -1.315 -1.308 7 736 3. §195.402 Procedural manual for operations, maintenance, and emergencies. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. Buckeye West Shore’s procedure for monitoring atmospheric corrosion does not provide specific 120165004_NOPV_PCP_PCO_06202016 Page 3 of 6#

120165004_NOPV PCP PCO_06202016_text.pdf, page 41-2016-5004 guidance on how to give particular attention to pipe under thermal insulation in accordance with §195.583(b). During the investigation, the PHMSA inspector reviewed Buckeye West Shore’s Corrosion Manual procedure A-04 Visual Pipe Inspection, issued 9/2013. The procedure states in part: “1. Policy 1.1 Visual inspections shall be conducted by trained and qualified field personnel to provide information concerning: 1.1.3 Condition of piping under thermal insulation or disbonded coating, at splash zones, or deck penetrations.” The procedure does not provide sufficient details on what areas of the insulated piping should be inspected, such as damaged insulation, low points on vertical runs, areas where pipe supports penetrate the insulation jacketing, or areas with caulking deterioration. In addition, the procedure did not provide adequate guidance on when portions of insulation should be removed to evaluate potential issues identified by visual observations. Buckeye West Shore stated that there was no other guidance on inspecting piping under thermal insulation in its written procedures. In addition, the PHMSA inspector reviewed Buckeye West Shore’s triennial atmospheric corrosion inspection records at its Granville Terminal, dated April 2013. The feed lines into West Shore Pipeline’s Granville Terminal are insulated. 1. There are seven jurisdictional pipelines running into the tank area. 2. According to the plant manager and the corrosion technician, the insulation has been in place since 2006. 3. 4. There are no ports for viewing the condition of representative pipe segments. There is no mention of inspecting the pipe under the thermal insulation. Buckeye West Shore stated that it had not removed the thermal insulation, nor inspected the piping under the insulation for corrosion since it has been installed in 2006. Proposed Civil Penalty 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. The Compliance Officer has reviewed the circumstances and supporting documentation involved in the above probable violation(s) and has recommended that you be preliminarily assessed a civil penalty of $ 105,400 as follows: Item number PENALTY 1 $61,200 2 $44,200 120165004_NOPV_PCP_PCO_06202016 Page 4 of 6#

120165004_NOPV PCP PCO_06202016_text.pdf, page 51-2016-5004 Proposed Compliance Order With respect to items 2 and 3, pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to West Shore Pipeline Company. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Response to this Notice 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. All material submitted in response to this enforcement action may be 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. In your correspondence on this matter, please refer to CPF 1-2016-5004 and for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Byron Coy, PE Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 120165004_NOPV_PCP_PCO_06202016 Page 5 of 6#

120165004_NOPV PCP PCO_06202016_text.pdf, page 61-2016-5004 PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to West Shore Pipeline Company (Buckeye West Shore) a Compliance Order incorporating the following remedial requirements to ensure the compliance of Buckeye West Shore with the pipeline safety regulations: 1. In regard to Item Number 2 of the Notice, pertaining to Buckeye West Shore’s failure to inspect and electrically test each electrical isolation, Buckeye West Shore must review and update its procedure A-05 Shorted Casing to provide guidance on remediating shorted casings. The procedures shall be revised within 30 days of receipt of the Final Order. 2. Buckeye West Shore shall remediate the shorted casings at the 2 locations identified in Item Number 2, in accordance with the revised procedures, within 12 months of issuance of the Final Order. 3. In regard to Item Number 3 of the Notice, pertaining to Buckeye West Shore’s failure to give particular attention to pipe coating under thermal insulation during atmospheric corrosion monitoring, Buckeye West Shore must review and update its procedure A-04 Visual Pipe Inspection to provide guidance for performing atmospheric corrosion inspections on pipelines under thermal insulation. The procedures shall be revised within 30 days of receipt of the Final Order. Buckeye West Shore shall inspect the piping under thermal insulation at the Granville Terminal, in accordance with the revised procedures, within 12 months of issuance of the Final Order. 4. Buckeye West Shore must complete the requirements as outlined above. All documentation demonstrating compliance with each of the items outlined in this proposed compliance order must be submitted to Byron Coy, PE, Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration, Suite 103, Bear Tavern Road, West Trenton, NJ for review. 5. It is requested (not mandated) that Buckeye West Shore maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Byron Coy, PE, Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. 120165004_NOPV_PCP_PCO_06202016 Page 6 of 6#

120165004_Final Order_11152016_text.pdf, page 1Official PDFMr. Clark C. Smith President and Chief Executive Officer Buckeye GP, LLC One Greenway Plaza Suite 600 Houston, Texas 77046 Re: CPF No. 1-2016-5004 Dear Mr. Smith: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violations, assesses a civil penalty of $105,400, and specifies actions that need to be taken by West Shore Pipe Line Company, which is operated by Buckeye Partners, L.P., to comply with the pipeline safety regulations. The penalty payment terms are set forth in the Final Order. When the civil penalty has been paid and the terms of the compliance order completed, as determined by the Director, Eastern Region, this enforcement action will be closed. Service of the Final Order by certified mail is deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Acting Associate Administrator for Pipeline Safety Enclosure cc: Mr. Byron Coy, Director, Eastern Region, OPS Mr. T. Scott Collier, VP, Performance Assurance & Asset Integrity, West Shore Pipeline Co. CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

120165004_Final Order_11152016_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ ) In the Matter of ) ) West Shore Pipe Line Co., ) CPF No. 1-2016-5004 ) Respondent. ) ____________________________________) FINAL ORDER From May 19, 2014 through July 31, 2015, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and records of the West Shore Pipe Line Company (West Shore or Respondent) in Breinigsville, PA. West Shore is a 650-mile common carrier petroleum pipeline system that originates in the greater Chicago area and transports refined petroleum products to northern Illinois and Wisconsin including the Madison and Green Bay, Wisconsin metropolitan markets.1 Buckeye Partners, L.P. operates the West Shore pipeline system on behalf of West Shore. As a result of the inspection, the Director, Eastern Region, OPS (Director), issued to Respondent, by letter dated June 20, 2016, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that West Shore had violated 49 C.F.R. §§ 195.402(a), 195.575(c), and 195.402(c)(3), and proposed assessing a civil penalty of $105,400 for the alleged violations. The Notice also proposed ordering Respondent to take certain measures to correct the alleged violations. West Shore responded to the Notice by letter dated July 18, 2016 (Response). The company did not contest the allegations of violation and agreed to pay the proposed civil penalty of $105,400, as provided in 49 C.F.R. § 190.227, upon issuance of the Final Order. Respondent did not request a hearing and therefore has waived the right to one. FINDINGS OF VIOLATION In its Response, Respondent did not contest the allegations in the Notice that it violated 49 C.F.R. Part 195, as follows: 1 Pipeline Safety Violation Report (Violation Report), (June 20, 2016) (on file with PHMSA), at 1.#

120165004_Final Order_11152016_text.pdf, page 3CPF No. 1-2016-5004 Page 2 Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 194.402(a), which states: § 195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) by failing to follow a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. Specifically, the Notice alleged that Respondent failed to follow its procedures for monitoring electrical isolation at casings along its pipeline system. Respondent’s Corrosion Manual procedure A-02 External Corrosion Control, versions 12/2012, 09/2012, and 12/2011, and procedure J-02 External Corrosion Control version 09/2010, Section 9.4 states: “Annually during the corrosion control survey, installed electrical isolation devices shall be inspected for proper operation.” The PHMSA inspector reviewed Respondent’s External Corrosion records for Line Segment EB252US-US254GT. The records indicate that Respondent failed to inspect electrical isolation devices for proper isolation at six locations. In an email dated July 31, 2015, Respondent provided additional details on the missed readings. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.402(a) by failing to follow its manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.575(c), which states: § 195.575 Which facilities must I electrically isolate and what inspections, tests, and safeguards are required? (a) You must electrically isolate each buried or submerged pipeline from other metallic structures, unless you electrically interconnect and cathodically protect the pipeline and the other structures as a single unit. (c) You must inspect and electrically test each electrical isolation to assure the isolation is adequate. The Notice alleged that Respondent violated 49 C.F.R. § 195.575(c) by failing to inspect and electrically test each electrical isolation at two casings along its pipeline system to assure the isolation is adequate. Specifically, the Notice alleged that in lieu of repairing shorted casing, Respondent monitored the casings with In-Line Inspection (ILI).#

120165004_Final Order_11152016_text.pdf, page 4CPF No. 1-2016-5004 Page 3 The PHMSA inspector reviewed Respondent’s External Corrosion records for Line Segment EB252US-US254GT. The records indicated that there were two locations (five instances) in which the potential difference between the pipe-to-soil readings on the casing and carrier pipes was less than 100 millivolts. In an email dated July 31, 2015, PHMSA asked Respondent to provide additional information for the two locations. Respondent responded as follows: Location 39.880: “This casing was tested using the Panhandle Eastern test method in 2010 (WO 640030) and found to be shorted. The casing is being monitored by ILI and last inspected in 2013. There has been no growth of external features within the casing and maximum pit depth is less than 15%. The pipeline displays adequate cathodic protection at this crossing.” Location 48.280: “This casing was tested using the Panhandle Eastern test method in 2008 and found to be shorted. The casing is being monitored by ILI and last inspected in 2013. No external corrosion features have been identified in this casing. The pipeline displays adequate cathodic protection at this crossing.” Monitoring the shorted casings with ILI in lieu of repairing the short does not meet the requirement of §195.575(c). Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.575(c) by failing to inspect and electrically test each electrical isolation at two casings along its pipeline system to assure the isolation is adequate. Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(3), which states: § 195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) . . . . (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. §195.583 What must I do to monitor atmospheric corrosion control? (a) . . . .#

120165004_Final Order_11152016_text.pdf, page 5CPF No. 1-2016-5004 Page 4 (b) During inspections you must give particular attention to pipe at soil-to-air interfaces, under thermal insulation, under disbonded coatings, at pipe supports, in splash zones, at deck penetrations, and in spans over water. The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(3) by failing to prepare and follow a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. Specifically, the Notice alleged that Respondent failed to prepare and follow a procedure for monitoring atmospheric corrosion that gives particular attention to pipe under thermal insulation in accordance with § 195.583(b). During the investigation, the PHMSA inspector reviewed Respondent’s Corrosion Manual procedure A-04 Visual Pipe Inspection, issued September 2013. The procedure did not explain what areas of the insulated piping should be inspected, such as damaged insulation, low points on vertical runs, areas where pipe supports penetrate the insulation jacketing, or areas with caulking deterioration. In addition, the procedure did not describe when portions of insulation should be removed to evaluate potential issues identified by visual observations. Respondent stated that there was no other guidance on inspecting piping under thermal insulation in its written procedures. In addition, the PHMSA inspector reviewed Respondent’s triennial atmospheric corrosion inspection records at its Granville Terminal, dated April 2013. The feed lines into Respondent’s Granville Terminal are insulated. Respondent stated that it had not removed the thermal insulation, nor inspected the piping under the insulation for corrosion since it has been installed in 2006. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.402(c)(3) by failing to prepare and follow a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. These findings of violations will be considered prior offenses in any subsequent enforcement action taken against Respondent. ASSESSMENT OF PENALTY Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed $200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any related series of violations. In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature, circumstances, and gravity of the violation, including adverse impact on the environment; the degree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect that the penalty may have on its ability to continue doing business; and the good faith of Respondent in attempting to comply with the pipeline safety regulations. In addition, I may consider the economic benefit gained from the violation without any reduction because of subsequent damages, and such other matters as justice may require. The Notice proposed a total#

120165004_Final Order_11152016_text.pdf, page 6CPF No. 1-2016-5004 Page 5 civil penalty of $105,400 for the violations cited above. Item 1: The Notice proposed a civil penalty of $61,200 for Respondent’s violation of 49 C.F.R. § 195.402(a) by failing to follow its procedures for monitoring electrical isolation at casings along its pipeline system. Respondent neither contested the allegation nor presented any evidence or argument justifying elimination of the proposed penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $61,200 for violation of 49 C.F.R. § 195.402(a). Item 2: The Notice proposed a civil penalty of $44,200 for Respondent’s violation of 49 C.F.R. § 195.575(c) by failing to inspect and electrically test each electrical isolation at two casings along its pipeline system to assure the isolation is adequate. Respondent neither contested the allegation nor presented any evidence or argument justifying elimination of the proposed penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $44,200 for violation of 49 C.F.R. § 195.575(c). In summary, having reviewed the record and considered the assessment criteria for each of the Items cited above, I assess Respondent a total civil penalty of $105,400. Payment of the civil penalty must be made within 20 days of service. Federal regulations (49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed instructions are contained in the enclosure. Questions concerning wire transfers should be directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, 6500 S MacArthur Blvd., Oklahoma City, Oklahoma 79169. The Financial Operations Division telephone number is (405) 954-8845. Failure to pay the $105,400 civil penalty will result in accrual of interest at the current annual rate in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to those same authorities, a late penalty charge of six percent (6%) per annum will be charged if payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty may result in referral of the matter to the Attorney General for appropriate action in a district court of the United States. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Items 2 and 3 in the Notice for violations of 49 C.F.R. §§ 195.575(c) and 195.402(c)(3) respectively. Under 49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its operations: 1. With respect to the violation of § 195.575(c) (Item 2), Respondent must review#

120165004_Final Order_11152016_text.pdf, page 7CPF No. 1-2016-5004 Page 6 and update its procedure A-05 Shorted Casing to include provisions that require remediating shorted casings. The procedures must be revised within 30 days of receipt of the Final Order. 2. With respect to the violation of § 195.575(c) (Item 2), Respondent must remediate the shorted casings at the 2 locations identified in Item Number 2, in accordance with the revised procedures, within 12 months of issuance of the Final Order. 3. With respect to the violation of § 195.402(c)(3) (Item 3), Respondent must give particular attention to pipe coating under thermal insulation during atmospheric corrosion monitoring. Respondent must review and update its procedure A-04 Visual Pipe Inspection to require performing atmospheric corrosion inspections on pipelines under thermal insulation. The procedures must be revised within 30 days of receipt of the Final Order. Respondent must inspect the piping under thermal insulation at the Granville Terminal, in accordance with the revised procedures, within 12 months of issuance of the Final Order. 4. Respondent must complete the requirements as outlined above. All documentation demonstrating compliance with each of the items outlined in this proposed compliance order must be submitted to Byron Coy, PE, Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration, Suite 103, Bear Tavern Road, West Trenton, NJ for review. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. In addition, pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is requested (not mandated) to take the following action: West Shore should maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Byron Coy, PE, Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses; and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. Failure to comply with this Order may result in the administrative assessment of civil penalties not to exceed $200,000 for each violation for each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States. Under 49 C.F.R. § 190.243, Respondent has a right to submit a Petition for Reconsideration of this Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA#

120165004_Final Order_11152016_text.pdf, page 8CPF No. 1-2016-5004 Page 7 will accept petitions received no later than 20 days after receipt of service of this Final Order by the Respondent, provided they contain a brief statement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The filing of a petition automatically stays the payment of any civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all other terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. ___________________________________ __________________________ Alan K. Mayberry Date Issued Acting Associate Administrator for Pipeline Safety#

120165004_Closure Letter_03262018_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY March 26, 2018 Mr. T. Scott Collier VP, Performance Assurance & Asset Integrity West Shore Pipeline Co. Five TEK Park 9999 Hamilton Boulevard Breinigsville, PA 18031 CPF 1-2016-5004 Dear Mr. Collier: On November 15, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to West Shore Pipeline Co., a Final Order in the above-referenced case. This Order included a Compliance Order and Civil Penalty assessment. Based on our review of the documentation you provided and confirmation of payment of the civil penalty, it has been determined that you have complied with the terms of this Order. Accordingly, this case is now closed and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#