BUCKEYE PARTNERS, LP — Warning Letter

party submissionOfficial PDF120185015W_Operator Response To Notice_05242018.pdf#

120185015W_Warning Letter_05102018_text.pdf, page 1Official PDFWARNING LETTER OVERNIGHT EXPRESS DELIVERY May 10, 2018 Thomas S. (Scott) Collier Vice President, Performance Assurance Buckeye Partners, L.P. Five TEK Park 9999 Hamilton Boulevard Breinigsville, PA 18031 CPF 1-2018-5015W Dear Mr. Collier: On June 27-28, 2017, an inspector from the New York State Department of Public Service (NYDPS), acting as Agent for the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Buckeye Partners, L.P.’s (Buckeye) Buckeye East System in New York. As a result of the inspection, it is alleged that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable violation(s) 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 inervals 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 failed to follow for each pipeline system a manual of written procedures for conducting#

120185015W_Warning Letter_05102018_text.pdf, page 2CPF 1-2018-5015W normal operations and maintenance activities. Specifically, Buckeye failed to follow Corrosion Control Manual C-02 Cathodic Protection Procedure, effective 04/11/2017 (Procedure C-02). The PHMSA representative reviewed Buckeye’s Procedure C-02. Section 7.4.1 Condition Inspection stated in part: “(3) Test the rectifier cabinet and junction boxes with voltmeter/voltage detector for presence of AC. Verify cabinet to soil voltage potential is less than 15 Volts AC. Ensure AC volt measurement is below 15 volts before touching the unit with your hand” During the field inspection, the PHMSA representative witnessed a rectifier inspection at 1600 Linden Boulevard, Brooklyn, New York (New Lots Junction Rectifier). The corrosion specialist did not use a voltmeter to test AC current prior to opening the rectifier box as required per Procedure C-02. Therefore, Buckeye failed to follow written Procedure C-02. 2. §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 inervals 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 failed to follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities. Specifically, Buckeye failed to follow O and M Manual F-27: Main Line Valves & Valve Sites, issued 6/14 (Procedure F-27). The PHMSA representative reviewed Buckeye’s Procedure F-27. Section 4 Leak Detection stated in part: “4.1 All mainline valves shall be inspected to verify that they are not leaking… 4.1.3 For direct-buried valves, if the site has an inspection tube, remove the cap and lower a hazardous gas detector/PID meter into the pit to check vapor level. If the tube has standing water, check for product sheen. If no inspection tube exists, probe on each side of the valve and use a PID meter with a pump/sample line to check the probed holes for vapor level.” The PHMSA representative witnessed a main line valve inspection at 1050 Forbell Street, Brooklyn, New York (Valve #45BK). Buckeye’s inspector did not use a hazardous gas detector nor PID meter to check vapor level as required per Procedure F-27. Therefore, Buckeye failed to follow written Procedure F-27. 120185015W_Warning Letter_05102018_text Page 2 of 3#

120185015W_Warning Letter_05102018_text.pdf, page 3CPF 1-2018-5015W Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $209,002 per violation per day the violation persists, up to a maximum of $2,090,022 for a related series of violations. For violations occurring prior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 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(s) identified in this letter. Failure to do so will result in Buckeye Partners, LP, being subject to additional enforcement action. Please 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). No reply to this letter is required. If you choose to reply, please submit all correspondence in this matter to Robert Burrough, Director, PHMSA Eastern Region, 820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer to CPF 1-2018-5015W on each document you submit, and whenever possible provide a signed PDF copy in electronic format. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on a CD accompanied by the original paper copy to the Eastern Region Office. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration 120185015W_Warning Letter_05102018_text Page 3 of 3#