{"operation":"document","citation":"CPF 120185024M","title":"BUCKEYE PARTNERS, LP — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-07-31","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(c)(3).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120185024m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120185024m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120185024m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120185024M","body":"Notice of Amendment involving BUCKEYE PARTNERS, LP. PHMSA's enforcement data identifies the cited regulation as 195.402(c)(3). The case was opened on 2018-07-31 and is reported as closed as of 2018-09-21. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120185024M_Closure Letter_09212018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185024M/120185024M_Closure%20Letter_09212018.pdf\n\n120185024M_Closure Letter_09212018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185024M/120185024M_Closure%20Letter_09212018_text.pdf\n\n120185024M_Notice of Amendment_07312018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185024M/120185024M_Notice%20of%20Amendment_07312018.pdf\n\n120185024M_Notice of Amendment_07312018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185024M/120185024M_Notice%20of%20Amendment_07312018_text.pdf\n\n120185024M_Operator Response to Notice And Request for Time Extension_08302018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120185024M/120185024M_Operator%20Response%20to%20Notice%20And%20Request%20for%20Time%20Extension_08302018.pdf\n\n120185024M_Notice of Amendment_07312018_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nJuly 31, 2018\nThomas S. (Scott) Collier\nVP, Performance Assurance and Asset Integrity\nBuckeye Partners, L.P.\nFive TEK Park\n9999 Hamilton Boulevard\nBreinigsville, PA 18031\nCPF 1-2018-5024M\nDear Mr. Collier:\nFrom June 22, 2017 to September 28, 2017, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), performed an integrated inspection of Buckeye Partners, L.P.’s (Buckeye) ‘Buckeye\nEast’ pipeline system located throughout Pennsylvania, New Jersey and New York.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacy found within\nBuckeye’s plans or procedures, as described below:\n1. § 195.402 Procedural manual for operations, maintenance, and emergencies.\n(c) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following to provide safety during\nmaintenance and normal operations:\n(3) Operating, maintaining, and repairing the pipeline in accordance with each of the\nrequirements of this subpart and subpart H of this part.\nBuckeye’s procedures for maintenance and normal operations are inadequate. Specifically,\nBuckeye’s 195 O and M Manual, Procedure F-33: Pressure Limiting and Control Devices\n(Control Valves, Relief Valves, Pressure Switches), dated 11/23/16, (Procedure) and associated\nrecord form failed to include adequate guidance for documenting the inspection and testing of\npressure transmitters in accordance with § 195.428(a).\n\n\n\nCPF 1-2018-5024M\nSection 195.428(a) states:\n(a) Except as provided in paragraph (b) of this section, each operator shall, at intervals not\nexceeding 15 months, but at least once each calendar year, or in the case of pipelines used\nto carry highly volatile liquids, at intervals not to exceed 7 ½ months, but at least twice\neach calendar year, inspect and test each pressure limiting device, relief valve, pressure\nregulator, or other item of pressure control equipment to determine that it is functioning\nproperly, is in good mechanical condition, and is adequate from the standpoint of capacity\nand reliability of operation for the service in which it is used.\nDuring the inspection, the PHMSA inspector reviewed Buckeye’s Procedure and associated\nrecords of inspection of pressure transmitters out of their work order system. Section 5.3 of the\nProcedure regarding pressure transmitter inspection and testing, did not include any documentation\nrequirements, such as required forms or minimum information to be recorded.\nThe work order records provided demonstrated documenting the following information:\n Device Tag Number and Description\n WO # and Description\n Date of Inspection\n Name of Person performing inspection\nThe Procedure and associated work order records failed to include guidance for documenting\ninformation such as:\n Device’s mechanical condition\n Design mA/mV to pressure span\n As found/as left mA/mV to pressure span\n Alarm(s) design set point(s)\n As found/as left alarm set points\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\n120185024M_Notice of Amendment_07312018_text Page 2 of 3\n\n\n\nCPF 1-2018-5024M\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Buckeye Partners, L.P. maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Director, PHMSA Eastern Region,\n820 Bear Tavern Road, Suite 103, West Trenton, NJ 08628. Please refer to CPF 1-2018-5024M\non each document you submit, and whenever possible provide a signed PDF copy in electronic\nformat. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should be sent on\na CD accompanied by the original paper copy to the Eastern Region Office.\nAdditionally, if you choose to respond to this (or any other case), please ensure that any response\nletter pertains solely to one CPF case number.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120185024M_Notice of Amendment_07312018_text Page 3 of 3\n\n120185024M_Closure Letter_09212018_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nSeptember 21, 2018\nThomas S. (Scott) Collier\nVP, Performance Assurance and Asset Integrity\nBuckeye Partners, L.P.\nFive TEK Park\n9999 Hamilton Boulevard\nBreinigsville, PA 18031\nCPF 1-2018-5024M\nDear Mr. Collier:\nFrom June 22, 2017 to September 28, 2017, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code\n(U.S.C.), performed an integrated inspection of Buckeye Partners, L.P.’s (Buckeye)\n‘Buckeye East’ pipeline system located throughout Pennsylvania, New Jersey and New York.\nAs a result of the inspection, Buckeye was issued a Notice of Amendment (NOA) dated\nJuly 31, 2018. Buckeye submitted its amended procedures on August 30, 2018. My staff has\nreviewed the amended procedures, and it appears that the inadequacy outlined in this Notice of\nAmendment has been corrected. In addition, we agree to the proposed effective date of\nApril 1, 2019 for the amended procedure.\nThis letter is to inform you that no further action is necessary, and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":8485}