{"operation":"document","citation":"CPF 120165013W","title":"BUCKEYE PARTNERS, LP — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2016-12-20","effective_on":null,"summary":"CLOSED warning letter citing 195.402(a), 195.589(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120165013w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120165013w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120165013w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120165013W","body":"Warning Letter involving BUCKEYE PARTNERS, LP. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.589(c). The case was opened on 2016-12-20 and is reported as closed as of 2016-12-20. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120165013W_Warning Letter_12202016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120165013W/120165013W_Warning%20Letter_12202016.pdf\n\n120165013W_Warning Letter_12202016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120165013W/120165013W_Warning%20Letter_12202016_text.pdf\n\n120165013W_Warning Letter_12202016_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nDecember 20, 2016\nThomas S. Collier\nVice President, Performance Assurance & Asset Integrity\nBuckeye Partners, L.P.\nFive TEK Park\n9999 Hamilton Boulevard\nBreinigsville, PA 18031\nCPF 1-2016-5013W\nDear Mr. Collier:\nFrom July 14 - 18, 2014, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code, inspected Buckeye\nPartners, L.P.’s (Buckeye) Jet Lines Unit # 20191 in Connecticut and Massachusetts.\nAs a result of the inspection, it appears that you have committed probable violations of the Pipeline\nSafety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable\nviolations are:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline commence, and\nappropriate parts shall be kept at locations where operations and maintenance\nactivities are conducted. Each transmission line or main must be constructed in\naccordance with comprehensive written specifications or standards that are\nconsistent with this part.\nBuckeye failed to follow, for each pipeline, a manual of written procedures for conducting normal\noperations and maintenance activities. Specifically, Buckeye failed to follow its O&M and\n\n\n\n1-2016-5013W\nDamage Prevention procedural manual Section 5.2.6 “If it is determined that the pipeline is\ninvolved at the planned excavation site.”\nDuring the inspection, the PHMSA inspector reviewed Buckeye’s Damage Prevention Procedure\nManual (DPPM) Issued 6/13, and inspection records for 2013 through 2014 associated with\nencroachment locations in CT where Buckeye was required to mark out its facilities.\nBuckeye’s DPPM Section 5 – One Call, paragraph 5.2.6.4 states that “Immediately after marking\nthe pipeline, a Buckeye Field representative shall take a digital photograph of Buckeye’s marked\npipeline to attach to the Work Order as proof that Buckeye pipeline was marked within the required\ntimeframe in case the markings are removed without authorization.”\nPipeline marking was required for three records. The PHMSA inspector requested the digital\nphotographs of Buckeye’s marked pipeline that are required by Buckeye’s procedure. For two of\nthe records, Buckeye could not provide any photographs of the marked pipelines. For the third\nrecord, the photographs provided did not depict the markouts.\nThus, Buckeye failed to follow its O&M and Damage Prevention procedures.\n2. §195.589 What corrosion control information do I have to maintain?\n(c) You must maintain a record of each analysis, check, demonstration, examination,\ninspection, investigation, review, survey, and test required by this subpart in\nsufficient detail to demonstrate the adequacy of corrosion control measures or that\ncorrosion requiring control measures does not exist. . .\nBuckeye failed to maintain an accurate record of each inspection required by this subpart in\nsufficient detail to demonstrate the adequacy of corrosion control measures or that corrosion\nrequiring control measures does not exist. Specifically, the condition of the coating on a 2-inch\nNPS fitting on a 12-inch diameter jet fuel line that crosses the Mattabesset River in Connecticut\nwas not accurately recorded on Buckeye’s exposed pipeline visual inspection form dated\n11/22/2013, as per §195.583(a).\nOn July 16, 2014, the PHMSA inspector conducted a field inspection of Buckeye’s Jet Lines ROW\nat a train bridge crossing located at the Mattabesset River north of Buckeye’s Middletown\nJunction. The bridge supports approximately 160 feet of aboveground uncased 12-inch diameter\npipe. The PHMSA inspector noted what appeared to be a 2-inch NPS fitting (aka 101 fitting) at\nthe 12 o’clock position on the north side of the pipe span, approximately 15 feet from the\nembankment. The coating on the 101 fitting had deteriorated, with approximately half the fitting\nshowing indications of coating failure and corrosion.\nThe PHMSA inspector reviewed Buckeye’s atmospheric corrosion control program and associated\nrecords from 2006 through 2013. Buckeye provided records for three inspections of the\naboveground exposed span RW913RYEP145242 as follows:\n1. Inspection record dated 11/22/2013. The condition of the coating was noted as ““Good –\nNo damage observed” and the condition of the pipe was noted as “no rust visible.”\n2. Inspection record dated 12/12/2012. The condition of the coating was noted as ““Good –\nNo damage observed” and the condition of the pipe was noted as “no rust visible.”\n3. Inspection record dated 9/26/2006. The remarks section of the record noted that “there is\na 101 fitting on the North side of the crossing. This should be removed as soon as\npractical. WO# 282580.”\n120165013W_Warning Letter_12202016 Page 2 of 3\n\n\n\n1-2016-5013W\nThe most recent Buckeye inspection record for the exposed span failed to note the poor condition\nof the coating and the corrosion of the 101 fitting.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $205,638\nper violation per day the violation persists up to a maximum of $2,056,380 for a related series of\nviolations. For violations occurring between January 4, 2012 to August 1, 2016, the maximum\npenalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed\n$2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the\nmaximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to\nexceed $1,000,000 for a related series of violations. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem identified in this letter. Failure to do so will result in Williams being subject to additional\nenforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2016-5013W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document, you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nRobert Burrough\nActing Director, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n120165013W_Warning Letter_12202016 Page 3 of 3","truncated":false,"body_characters":7854}