BUCKEYE PARTNERS, LP — Safety Order

120195012S_Consent Agreement and Order_04272020_text.pdf, page 1Official PDFApril 27, 2020 VIA ELECTRONIC MAIL TO: ccsmith@buckeye.com Mr. Clark C. Smith President and Chief Executive Officer Buckeye Partners, LP 1 Greenway Plaza, Suite 600 Houston, Texas 77046 CPF No. CPF 1-2019-5012S Dear Mr. Smith: Enclosed please find a Consent Order incorporating the terms of the Consent Agreement between the Pipeline and Hazardous Materials Safety Administration (PHMSA) and Buckeye Partners, LP, which was executed on April 27, 2020. Service of the Consent Order and Consent Agreement by electronic mail is deemed effective upon the date of transmission as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure: Order and Consent Agreement cc: Mr. Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, PHMSA Mr. Carl Ostach, Vice President, Domestic Operations, Buckeye Partners, LP, costach@buckeye.com Mr. Patrick Monaghan, Associate General Counsel and Chief Compliance Officer, Buckeye Partners, LP, pmonaghan@buckeye.com Ms. Claudia Pankowski, Director of Regulatory Compliance, Buckeye Partners, LP, cpankowski@buckeye.com CONFIRMATION OF RECEIPT REQUESTED#

120195012S_Consent Agreement and Order_04272020_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 ) Buckeye Partners, LP, ) CPF No. 1-2019-5012S ) ) ) Respondent. ) ____________________________________) CONSENT ORDER By letter dated December 5, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety, issued a Notice of Proposed Safety Order (Notice) to Buckeye Partners, LP (Respondent). In accordance with 49 C.F.R. § 190.239, the Notice alleged that conditions exist on Respondent’s MU720DT (Line 720) pipeline near Marklesburg, Pennsylvania, that pose a pipeline integrity risk to public safety, property, or the environment. The Notice proposed that Respondent take certain corrective measures to remedy the alleged conditions and ensure that the public, property, and the environment are protected from the potential risk. In response to the Notice, Respondent requested an informal consultation, whereupon the parties engaged in good-faith settlement discussions that have resulted in the Consent Agreement attached to this Consent Order that settles all of the allegations in the Notice. Accordingly, the Consent Agreement is hereby approved and incorporated by reference into this Consent Order. The Respondent is hereby ordered to comply with the terms of the Consent Agreement, effective immediately. Pursuant to 49 U.S.C. 60101, et seq., failure to comply with this Consent Order may result in the assessment of civil penalties of up to $200,000, as adjusted for inflation (see 49 C.F.R. § 190.223), 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. The terms and conditions of this Consent Order are effective upon service in accordance with 49 C.F.R. § 190.5. April 27, 2020 Alan K. Mayberry Date Associate Administrator for Pipeline Safety#

120195012S_Consent Agreement and Order_04272020_text.pdf, page 3U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ ) In the Matter of ) ) Buckeye Partners, LP, ) CPF No. 1-2019-5012S ) Respondent. ) ) CONSENT AGREEMENT On December 5, 2019, pursuant to 49 C.F.R. § 190.239, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS or Agency), issued a Notice of Proposed Safety Order (Notice) to Buckeye Partners, LP (Buckeye or Respondent). The Notice alleged that conditions existed on Respondent’s MU720DT (Line 720) pipeline near Marklesburg, Pennsylvania, that posed a pipeline integrity risk to public safety, property, or the environment. Specifically, the Notice alleged that PHMSA had initiated an investigation and information review of Line 720 following notification from the National Response Center (NRC) on November 18, 2019, that Line 720 had experienced a release of approximately 650 barrels of gasoline near Marklesburg, Pennsylvania. The Notice did not cite a cause of the accident but noted that the company had submitted a safety-related condition report to PHMSA several months earlier, identifying 33 features meeting Buckeye’s “immediate repair condition” criteria and that the failure had occurred at the site of a recent repair. The Notice also proposed that Respondent take certain corrective measures to remedy the alleged conditions and ensure that the public, property, and the environment are protected from the potential risk. On December 13, 2019, Buckeye responded to the Notice by timely submitting a written response and a request for an informal consultation under 49 C.F.R. § 190.239(b)(2). An informal consultation was held on February 20, 2020, at PHMSA’s Eastern Region Office in West Trenton, New Jersey. As a result of the informal consultation, PHMSA and Buckeye (collectively, Parties) agreed that settlement of this proceeding would avoid further administrative proceedings or litigation of the Notice and that entry into this Consent Agreement (Agreement) would be the most appropriate means of resolving the issues raised in the Notice and would generally be in the public interest. Therefore, pursuant to 49 C.F.R. Part 190, without adjudication of any issue of fact or law, and upon consent and agreement of Buckeye and PHMSA, the Parties agree as follows:#

120195012S_Consent Agreement and Order_04272020_text.pdf, page 4CPF 1-2019-5012S Page 2 I. General Provisions 1. Respondent acknowledges that as the operator of Line 720, Buckeye and its Line 720 are subject to the jurisdiction of the Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and administrative orders issued thereunder. For purposes of this Agreement, Respondent acknowledges that it received proper notice of PHMSA’s action in this proceeding and that the Notice states claims upon which relief may be granted pursuant to 49 U.S.C. § 60101, et seq., and the regulations and orders issued thereunder. Line 720 is a 20-inch diameter line which transports refined liquid petroleum products and runs approximately 77 miles from Mechanicsburg, Pennsylvania, to Duncansville, Pennsylvania. The line is part of a 175-mile pipeline system running from Reading, Pennsylvania, to Altoona, Pennsylvania. The “Affected Segment” of Line 720 is defined in Paragraph 12 of this Agreement. 2. Respondent agrees, for purposes of this Agreement, to address the integrity risks identified in the Notice by completing the actions specified in Section II of this Agreement (Corrective Measures) and to abide by the terms of this Agreement. This Agreement does not constitute a finding of violation of any Federal law or regulation and may not be used in any civil or administrative proceeding of any kind as evidence or proof of any fact, fault or liability, or as evidence of the violation of any law, rule, regulation or requirement, except in a proceeding to enforce the provisions of this Agreement. 3. After Respondent returns this signed Agreement to PHMSA, the Agency’s representative will present it to the Associate Administrator for Pipeline Safety, recommending that the Associate Administrator adopt the terms of this Agreement by issuing an administrative order (Consent Order) incorporating the terms of this Agreement. The terms of this Agreement constitute an offer of settlement until accepted by the Associate Administrator. Once accepted, the Associate Administrator will issue a Consent Order incorporating the terms of this Agreement. 4. Respondent consents to the issuance of the Consent Order incorporating this Consent Agreement, and hereby waives any further procedural requirements with respect to their issuance. Respondent waives all rights to contest the adequacy of notice, or the validity of the Consent Order or this Agreement, including all rights to administrative or judicial hearings or appeals, except as set forth herein. 5. This Agreement will apply to and be binding upon PHMSA, and upon Buckeye, its officers, directors, and employees, and its successors, assigns, or other entities or persons otherwise bound by law. Respondent agrees to provide a copy of this Agreement and any incorporated work plans and schedules to all of Buckeye’s officers, employees, and agents whose duties might reasonably include compliance with this Agreement. 6. For any transfer of ownership or operating responsibility of Buckeye’s Line 720, Respondent will provide a copy of this Agreement to the prospective transferee at least#

120195012S_Consent Agreement and Order_04272020_text.pdf, page 5CPF 1-2019-5012S Page 3 30 days prior to such transfer and provide written notice of the transfer within 30 days to the PHMSA Eastern Region Director (Director) who issued the Notice. 7. This Agreement constitutes the final, complete and exclusive agreement and understanding between the Parties with respect to the settlement embodied in this Agreement. The Parties acknowledge that there are no representations, agreements or understandings relating to settlement other than those expressly contained in this Agreement, except that the terms of this Agreement may be construed by reference to the Notice. 8. Nothing in this Agreement affects or relieves Respondent of its responsibility to comply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and orders issued thereunder. Nothing in this Agreement alters PHMSA's right of access, entry, inspection, and information gathering or PHMSA’s authority to bring enforcement actions against Buckeye pursuant to the Federal pipeline safety laws, the regulations and orders issued thereunder, or any other provision of Federal or State law. 9. This Agreement does not waive or modify any Federal, State, or local laws or regulations that are applicable to Respondent’s pipeline systems. This Agreement is not a permit, nor a modification of any permit, under any Federal, State, or local laws or regulations. Buckeye remains responsible for achieving and maintaining compliance with all applicable Federal, State, and local laws, regulations and permits. 10. This Agreement does not create rights in, or grant any cause of action to, any third party not party to this Agreement. The U.S. Department of Transportation is not liable for any injuries or damages to persons or property arising from acts or omissions of Respondent or its officers, employees, or agents carrying out the work required by this Agreement. Buckeye agrees to hold harmless the U.S. Department of Transportation, its officers, employees, agents, and representatives from any and all causes of action arising from any acts or omissions of Buckeye or its contractors in carrying out any work required by this Agreement. 11. Upon issuance of the Consent Order, Buckeye agrees to perform the Corrective Measures set forth below. 12. Definitions A. The “Affected Segment” means the approximately 77 miles of Buckeye’s 20- inch Line 720 pipeline running from the upstream Mechanicsburg Pump Station (Mile Post 107.4) near Mechanicsburg in Cumberland County, Pennsylvania, through the downstream Duncansville Pump Station (MP 184.7) near Duncansville in Blair County, Pennsylvania. The “Affected Segment” generally runs westerly through portions of Cumberland, Perry, Juniata, Huntingdon, and Blair Counties in Pennsylvania.#

120195012S_Consent Agreement and Order_04272020_text.pdf, page 6CPF 1-2019-5012S Page 4 B. The “Director” means the Director, Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety, Eastern Region. The Director’s address is 840 Bear Tavern Road, Suite 300, West Trenton, New Jersey 08628. C. The “Failure” means the release of approximately 650 barrels of gasoline that occurred on Buckeye’s 20-inch Line 720, which the NRC reported to PHMSA on November 18, 2019. II. Corrective Measures Buckeye agrees to take the following corrective measures to address the Preliminary Findings and Proposed Corrective Actions set forth in the Notice, as follows: 1. 2. 3. 4. Pressure Reduction. Buckeye shall maintain the existing operating-pressure reduction for the Affected Segment that was initiated at the time of its filing the August 23, 2019 safety-related condition report with PHMSA. This pressure reduction is based on 80% of the maximum pressure experienced in the 60 days prior to the in-line inspection (ILI) tool trap date from Line 720’s July 12, 2019 assessment. Removal of Pressure Restriction. The Director may allow the removal or modification of the pressure restriction upon a written request from Respondent demonstrating that restoring the pipeline to its normal operating pressure is justified based on a reliable engineering analysis showing that the pressure increase is safe, considering all known defects, anomalies, and operating parameters of the pipeline. The Director may also consider a demonstration that temporary mitigative and preventive measures are implemented prior to and during the temporary removal or modification of the pressure restriction. The Director's determination will be based on the determined cause of the Failure and evidence of the analyses and measures taken. Review of Affected Segment. Buckeye must review and inspect the Affected Segment for conditions similar to those of the Failure or other Buckeye-determined immediate conditions it discovers, including a review of operating and maintenance and integrity management records, such as, but not limited to, ILI results, hydrostatic tests, a root cause failure analysis (RCFA) of the Failure, aerial and ground patrols, excavations, and pipe replacements. Respondent must address any findings that require remedial measures to be implemented within 30 days of discovery. Metallurgical Testing. In accordance with the Notice, on March 30, 2020, Respondent delivered to the Director a metallurgical testing report on the pipe joint that failed, entitled Metallurgical Analysis of Leak at Girth Weld on 20-Inch Diameter 720L, prepared by DVN-GL and dated March 27, 2020 (Metallurgical Report). Prior to finalization of the Metallurgical Report, Respondent asked DVN-GL to simultaneously provide a draft of the report, dated February 4, 2020, to PHMSA. Respondent maintained chain-of-custody documentation for transporting the pipe to the DVN-GL laboratory, and the metallurgical analysis followed established testing protocols.#

120195012S_Consent Agreement and Order_04272020_text.pdf, page 7CPF 1-2019-5012S Page 5 5. 6. Additionally, arrangements were made to provide PHMSA with the opportunity for a PHMSA representative to observe the metallurgical testing. Root Cause Failure Analysis. Within 90 days following receipt of this Agreement and Order, Buckeye must complete a RCFA and submit a final report of this RCFA to the Director. The RCFA must be supplemented and facilitated by an independent third party with prior written approval of the Director, and must document the decision- making process used in the analysis and all factors contributing to the Failure. The final report must include findings, any lessons learned, and whether the findings and lessons learned are applicable to other locations within Buckeye’s pipeline system. Remedial Work Plan. Within 90 days following receipt of this Agreement and Order, Buckeye must submit a Remedial Work Plan (RWP) to the Director for approval. The Director may approve the RWP incrementally without approving the entire RWP. Buckeye must revise the RWP as necessary to incorporate new information obtained during the Failure investigation and remedial activities, to incorporate the results of actions undertaken pursuant to this Agreement, and to incorporate modifications required by the Director. Buckeye must submit any such plan revisions to the Director for prior approval. The Director may approve plan revisions incrementally. Once approved by the Director, the RWP, and any revisions, will be incorporated by reference into this Agreement. Buckeye must implement the RWP as approved by the Director, including any revisions to the plan. The RWP must: A. Specify the tests, inspections, assessments, evaluations, and remedial measures Buckeye will use to verify the integrity of the Affected Segment. It must address all known or suspected factors and causes of the Failure. Buckeye should consider both the risk and potential consequence of another failure to develop a prioritized schedule for RWP-related work along the Affected Segment. B. Include a procedure or process to identify pipe in the Affected Segment with characteristics similar to the contributing factors identified for the Failure. C. Include a procedure or process to gather all data necessary to review the failure history (in service and pressure test failures) of the Affected Segment and to prepare a written report containing all the available information such as the locations, dates, and causes of leaks and failures. D. Include a procedure or process to integrate the results of the metallurgical testing, RCFA, and other corrective actions required by this Agreement with all relevant pre-existing operational and assessment data for the Affected Segment. Pre-existing operational data includes, but is not limited to, construction, operations, maintenance, testing, repairs, prior metallurgical analyses, and any third-party consultation information. Pre-existing assessment data includes, but is not limited to, ILI tool runs, hydrostatic pressure testing, direct assessments, close interval surveys, and DCVG/ACVG surveys.#

120195012S_Consent Agreement and Order_04272020_text.pdf, page 8CPF 1-2019-5012S Page 6 E. Include a procedure or process to determine if conditions similar to those contributing to the Failure are likely to exist elsewhere on the Affected Segment. F. Based on the results of the like and similar condition review, Buckeye shall: i. Develop excavation prioritization criteria and perform inspections; ii. Add the Affected Segment to the Buckeye Integrity Management Plan Pipeline Supplemental Field Inspections protocol and commit to manage the issue within its integrity management plan; and iii. Evaluate the benefit of including inertial mapping unit tools to assist with strain measurements. G. Include a procedure or process to conduct additional field tests, inspections, assessments, and/or evaluations to determine whether, and to what extent, the conditions associated with the Failure or any other integrity threats are present elsewhere on the Affected Segment. At a minimum, this process must consider all failure causes and specify the use of one or more of the following: i. ILI tools that are technically appropriate for assessing the pipeline system based on the cause of the Failure, and that can reliably detect and identify anomalies; ii. Hydrostatic pressure testing; iii. Close-interval surveys; iv. Cathodic protection surveys, to include interference surveys in coordination with other utilities (e.g. underground utilities, overhead power lines, etc.) in the area; v. Coating surveys; vi. Stress corrosion cracking surveys; vii. Selective seam corrosion surveys; and, viii. Other tests, inspections, assessments, and evaluations appropriate for the Failure causes. Note: Buckeye may use the results of previous tests, inspections, assessments, and evaluations if approved by the Director, provided the results of the tests, inspections, assessments, and evaluations are analyzed with regard to the factors known or suspected to have caused the Failure.#

120195012S_Consent Agreement and Order_04272020_text.pdf, page 9CPF 1-2019-5012S Page 7 H. Describe the inspection and repair criteria Buckeye will use to prioritize, excavate, evaluate, and repair anomalies, imperfections, and other identified integrity threats. Include a description of how any defects will be graded and a schedule for repairs or replacement. I. Based on the known history and condition of the Affected Segment, describe the methods Buckeye will use to repair, replace, or take other corrective measures to remediate the conditions associated with the Failure, and to address other known integrity threats along the Affected Segment. The repair, replacement, or other corrective measures must meet the criteria specified in paragraph H, above. J. Include a procedure or process to implement continuing long-term periodic testing and integrity verification measures to ensure the ongoing safe operation of the Affected Segment, considering the results of the analyses, inspections, evaluations, and corrective measures undertaken pursuant to this Agreement. K. Include a proposed schedule for completion of the RWP. 7. Schedule. The RWP must include a proposed timeline for completion of Corrective Measures required in Paragraph 18. 8. Documentation. Respondent will retain on file documentation of compliance with the RWP. Respondent will provide copies of such documentation to the Director upon written request. 9. Monthly Reports. Buckeye must submit monthly reports to the Director that: (1) include analyses of all available data and results of the testing and evaluations required by this Agreement; (2) describe the progress of repairs and other remedial actions being undertaken; and (3) document all mandated actions and management of change plans to ensure that all procedural modifications are incorporated into Buckeye’s operations and maintenance procedures manual. The first report will be due 30 days from issuance of the Order. 10. Consent Agreement Documentation Report (CADR). When Buckeye has completed all the items in this Agreement it will submit a final CADR in its entirety to the Director. This will allow the Director to conduct a thorough review of all actions taken by Buckeye with regards to this Agreement prior to approving the closure of this Agreement. The intent is for the CADR to summarize all activities and documentation associated with this Agreement in one document. A. The Director may approve the CADR incrementally without approving the entire CADR. B. The CADR must include but is not limited to:#

120195012S_Consent Agreement and Order_04272020_text.pdf, page 10CPF 1-2019-5012S Page 8 i. Table of Contents; ii. Summary of the Failure, and the response activities; iii. Summary of pipe data/properties and all prior assessments of the Affected Segment; iv. Summary of all tests, inspections, assessments, evaluations, and analysis required by this Agreement; v. Summary of the mechanical and metallurgical testing as required by this Agreement; vi. Summary of the RCFA with all root causes as required by this Agreement; vii. Documentation of all actions taken by Buckeye to implement the RWP, the results of those actions, and the inspection and repair criteria used; viii. Documentation of any revisions to the RWP including those necessary to incorporate the results of actions undertaken pursuant to this Agreement and whenever necessary to incorporate new information obtained during the Failure investigation and remedial activities; ix. Lessons learned while completing this Agreement; x. A path forward describing specific actions Buckeye will take on its entire pipeline system as a result of the lessons learned from work on this Agreement; and xi. Appendices (if required). 11. Extensions of Time. The Director may grant an extension of time for compliance with any of the terms of this Agreement upon a written request timely submitted demonstrating good cause for an extension. The Director will respond in writing to any such request. 12. Documentation of Costs. It is requested (not mandated) that Respondent maintain documentation of the safety improvement costs associated with fulfilling this Agreement and submit the total to the 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. III. Review and Approval Process#

120195012S_Consent Agreement and Order_04272020_text.pdf, page 11CPF 1-2019-5012S Page 9 1. With respect to any submission under Section II (Corrective Measures) of this Agreement that requires the approval of the Director, the Director may: (a) approve, in whole or in part, the submission; (b) approve the submission on specified, reasonable conditions; (c) disapprove, in whole or in part, the submission; or (d) any combination of the foregoing. If the Director approves, approves in part, or approves with conditions, Buckeye will take all action as approved by the Director, subject to Respondent’s right to invoke the dispute resolution procedures with respect to any conditions the Director identifies. If the Director disapproves all or any portion of the submission, the Director will provide Buckeye with a written notice of the deficiencies. Respondent will correct all deficiencies within the time specified by the Director and resubmit it for approval. IV. Dispute Resolution 1. The Director and Buckeye will informally attempt to resolve any disputes arising under this Agreement. If Respondent and the Director are unable to informally resolve the dispute within 15 business days, Respondent may request in writing, within 10 days, a written determination resolving the dispute from the Associate Administrator for Pipeline Safety, PHMSA. Along with its request, Respondent will provide all information that Respondent reasonably believes is relevant to the dispute. If the request is submitted as provided herein, the Associate Administrator will issue a written determination that shall constitute final agency action. The existence of a dispute and PHMSA’s consideration of matters placed in dispute shall not excuse, toll, or suspend any term or timeframe for completion of any work to be performed under this Agreement during pendency of the dispute resolution process, except as agreed by the Director or the Associate Administrator in writing. V. Enforcement 1. This Agreement, as adopted by the Consent Order, is subject to all enforcement authorities available to the PHMSA under 49 U.S.C. § 60101, et seq., and 49 C.F.R. Part 190. All work plans and associated schedules set forth or referenced in Section II will be automatically incorporated into this Agreement and are enforceable in the same manner. VI. Recordkeeping and Information Disclosure 1. Unless otherwise required in this Agreement, Buckeye agrees to maintain records demonstrating compliance with all requirements of this Agreement for a period of at least five years following completion of all work to be performed. For any reports, plans, or other deliverables required to be submitted to PHMSA pursuant to this Agreement, Respondent may assert a claim of business confidentiality or other protections applicable to the release of information by PHMSA, covering part or all of the information required to be submitted to PHMSA pursuant to this Agreement in accordance with 49 C.F.R. Part 7. Respondent must mark the claim of confidentiality in writing on each page, and include a statement specifying the grounds for each claim#

120195012S_Consent Agreement and Order_04272020_text.pdf, page 12CPF 1-2019-5012S Page 10 of confidentially. PHMSA will determine the release of any information submitted pursuant to this Agreement in accordance with 49 C.F.R. Part 7, the Freedom of Information Act, 5 U.S.C. § 552, DOT and PHMSA policies, and other applicable regulations and Executive Orders. VII. Effective Date 1. The term “Effective Date,” as used herein, is the date on which the Consent Order is issued by the Associate Administrator incorporating the terms of this Agreement. Unless specified to the contrary, all deadlines for actions required by this Agreement run from the Effective Date of the Consent Order. VIII. Modification 1. The terms of this Agreement may be modified by mutual agreement of the Parties. Such modifications must be in writing and signed by both parties. IX. Termination 1. This Agreement and Order terminates upon completion of the Corrective Measures and other actions within Section II, as determined by the Director. Buckeye may request written confirmation from PHMSA when this Agreement and Order are terminated and the Director will provide such confirmation within a reasonable time. Nothing in this Agreement prevents Respondent from completing any of the obligations earlier than the deadlines provided for in this Agreement. X. Ratification 1. 2. The Parties’ undersigned representatives certify that they are fully authorized to enter into the terms and conditions of this Agreement and to execute and legally bind such party to this document. The Parties hereby agree to all conditions and terms of this Agreement. For Buckeye Partners, LP (Respondent): April 21, 2020 _________________________________ ____________________________ Clark C. Smith Date President and CEO Buckeye Partners, LP For PHMSA:#

120195012S_Consent Agreement and Order_04272020_text.pdf, page 13CPF 1-2019-5012S Page 11 April 27, 2020 ___________________________________ ___________________________ Alan K. Mayberry Date Associate Administrator for Pipeline Safety Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation#

120195012S_Notice of Proposed Safety Order_12052019_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY December 5, 2019 Mr. Carl Ostach VP, Domestic Operations Buckeye Partners, LP 9999 Hamilton Blvd, Suite 260 Breinigsville, PA 18031 CPF 1-2019-5012S Dear Mr. Ostach: Enclosed is a Notice of Proposed Safety Order (Notice) issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) in the above-referenced case. The Notice proposes that you take certain measures with respect to Buckeye Partners, LP’s (Buckeye) MU720DT (Line 720) pipeline near Marklesburg, PA. Your options for responding are set forth in the Notice. Your receipt of the Notice constitutes service of that document under § 190.5. We look forward to a successful resolution to ensure pipeline safety. Please direct any questions on this matter to me at 609-771-7809. Thank you for your cooperation in this matter. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Notice of Proposed Safety Order Copy of 49 C.F.R. § 190.239 cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, PHMSA Mr. Robert A Malecky, President, Domestic Pipelines and Terminals, Buckeye Partners, LP; 9999 Hamilton Blvd, Suite 260 Breinigsville, PA 18031#

120195012S_Notice of Proposed Safety Order_12052019_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 ) Buckeye Partners, LP, ) a subsidiary of IFM Investors, ) CPF No. 1-2019-5012S ) ) ) Respondent. ) _________________________________________ ) NOTICE OF PROPOSED SAFETY ORDER Background and Purpose: Pursuant to Chapter 601 of Title 49, United States Code, the Pipeline and Hazardous Materials Safety Administration (PHMSA), U.S. Department of Transportation, has initiated an investigation and information review of the safety of Buckeye Partners, LP’s (Buckeye) 20-inch MU720DT (Line 720) hazardous liquids pipeline system. The investigation was prompted after PHMSA was notified on November 18, 2019, by the National Response Center of a reportable accident that occurred on Buckeye’s 20-inch Line 720 pipeline, which resulted in the release of approximately 650 barrels (bbl) of gasoline (the Failure). The Failure occurred in a remote location and there were no reported injuries, fatalities or evacuations and no product ignition occurred. The cause of the Failure has not yet been determined. As a result of the preliminary investigation, it appears conditions exist on your pipeline system that pose an integrity risk to public safety, property, or the environment. Pursuant to 49 U.S.C. § 60117(l), PHMSA, Office of Pipeline Safety (OPS), issues this Notice of Proposed Safety Order (Notice), notifying you of the preliminary findings of the investigation, and proposing that you take certain measures to ensure that the public, property, and the environment are protected from this integrity risk. For the purposes of this Notice: Page 2 of 12#

120195012S_Notice of Proposed Safety Order_12052019_text.pdf, page 3“Affected Segment” means the approximately 77 miles of Buckeye’s 20-inch Line 720 pipeline from the upstream Mechanicsburg Pump Station (Mile Post 107.4) near Mechanicsburg in Cumberland County, Pennsylvania, through the downstream Duncansville Pump Station (MP 184.7) near Duncansville in Blair County, Pennsylvania. The “Affected Segment” generally runs westerly through portions of Cumberland, Perry, Juniata, Huntingdon, and Blair Counties in Pennsylvania. "Isolated Segment" means the approximately 2.8-mile segment of Buckeye’s 20-inch Line 720 pipeline from the Clover Creek Road motor-operated valve (CCMOV) at pipeline station number 9085+61 (downstream of the Failure) to the Redstone Ridge Road manually-operated gate valve (RRV) at pipeline station number 8939+22 (upstream of the Failure). It is the portion of the “Affected Segment” that was shut-in after the Failure on November 18, 2019. "Director" means the Director, Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety, Eastern Region. The Director’s address is 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628 Preliminary Findings:  Buckeye operates approximately 6,000 miles of pipeline located primarily in the northeastern and upper Midwestern portions of the United States, and services over 100 delivery locations. These pipelines primarily transport liquid petroleum products, including gasoline, jet fuel and a variety of distillates, from major supply sources to terminals and airports located within end-use markets. Buckeye has 110 active terminals that provide bulk storage and throughput services with respect to liquid petroleum products and renewable fuels, including ethanol, and have an aggregate tank capacity of over 56 million barrels. 1  Buckeye is a wholly-owned subsidiary of IFM Investors, an investment management company.2  On August 23, 2019, Buckeye submitted a Safety-Related Condition Report to PHMSA for Line 720. The report indicated that the line was assessed with a combination Geometry (GEO) and Axial Magnetic Flux Leakage (AMFL) in-line inspection (ILI) tool run on July 12, 2019. Upon receipt of the preliminary ILI report, Buckeye discovered 33 features meeting Buckeye’s immediate condition criteria under its integrity management program 1 Buckeye Partners Website, available at https://www.buckeye.com/BusinessOperations/PipelineTransportationOperations/tabid/584/Default.aspx/ (last accessed November 25, 2019). 2 IFM acquired Buckeye on November 1, 2019. Buckeye Partners website, available at https://www.buckeye.com/LinkClick.aspx?fileticket=hMppeiwfjnw%3d&tabid=36 (last accessed November 25, 2019). Page 3 of 12#

120195012S_Notice of Proposed Safety Order_12052019_text.pdf, page 4required in 49 C.F.R. § 195.452.  The failed pipeline, Line 720, is a 20-inch diameter line which transports refined liquid petroleum products and runs approximately 77 miles from Mechanicsburg, PA, to Duncansville, PA. The line is part of a 175-mile pipeline system which runs from Reading, PA to Altoona, PA. The Failure occurred one mile northwest of Marklesburg, PA, along a steep slope of Tussey Mountain. The nearest road is Mountain Rd in Huntingdon County.  The section of the Affected Segment near the Failure site was constructed in 1958. The pipeline at the Failure site section consists of grade X-52, 20” seamless steel pipe manufactured by National Tube, with a wall thickness of 0.281”. The pipeline is protected by an impressed current cathodic protection system. In the area of the Failure site, the pipeline has a coal tar enamel coating.  The maximum operating pressure (MOP) of the Affected Segment is 1045 psig. At the time of the Failure, the actual operating pressure for Line 720 at the top of the slope near the Failure site was 70 psig, and 500 psig at the bottom of the slope.  At approximately 7:05 a.m. EST on November 18, 2019, a work crew returning to the site where they had been conducting ILI-based repairs on Line 720 in the weeks prior noticed the smell of gasoline and began implementing Buckeye’s emergency response protocol. The loss of pressure and product caused by the Failure was not identified by Buckeye’s SCADA system alarms. The Failure is in a remote location on the side of a steep hill. There were no reported injuries, fatalities, or evacuations, and the gasoline did not ignite.  Buckeye’s Control Center was notified and immediately shut down Line 720. The Isolated Segment was shut-in via the CCMOV and RRV, and currently remains out of service. The CCMOV was closed at 7:10 a.m. EST, and the RRV was closed shortly after. Mountain road was closed at approximately 8:00 a.m. EST by the local Fire Department.  Initial calculations indicated a release volume of 650-barrels from the site of a recent repair. Containment of the release was difficult due to the product flowing between the cracked clay soil and rocky subsoil. As of 7:00 a.m. EST on November 25, 2019, 221- barrels of product were reported to have been recovered.  Buckeye indicated that the low flow rate of the leak was below the detectable limit for Line 720’s LeakWarn leak detection system, and thus the leak was not discovered by its control room.  The PHMSA investigation is ongoing and the cause of the Failure is unknown at this time. The leak has been determined to originate from beneath an approximately 11.5-foot Type- Page 4 of 12#

120195012S_Notice of Proposed Safety Order_12052019_text.pdf, page 5A steel repair sleeve installed during the week of November 5 to November 8, 2019. The sleeve was installed to repair 2 top side dents with associated metal loss which met Buckeye’s criteria for immediate conditions outside of High Consequence Areas (HCAs).  On November 25, 2019, 160 feet of pipe containing multiple recent and legacy repairs were cut out from the pipeline. The cutout section included 13 recently repaired Buckeye immediate conditions for topside dents with metal loss in non-HCAs. This included the pipe joint at the Failure site with the 11.5-foot Type-A sleeve in place and unaltered. This specimen will be taken to the DNV GL lab in Dublin, Ohio for metallurgical analysis.  Buckeye completed repair of the pipe segment using three (3) joints of pre-tested pipe on November 26, 2019. Buckeye provided a refill and restart plan, which included conducting a 1-hour pressure hold test to verify integrity. The line was returned to service at 80% of the maximum pressure experienced in the 60 days prior to the ILI tool trap date from Buckeye’s July 12, 2019 assessment of Line 720. Proposed Issuance of Safety Order: Section 60117(1) of Title 49, United States Code, provides for the issuance of a safety order, after reasonable notice and the opportunity for a hearing, requiring corrective action, which may include physical inspection, testing, repair, replacement, or other action, as appropriate. The basis for making the determination that a pipeline facility has a condition or conditions that pose a pipeline integrity risk to public safety, property, or the environment is set forth both in the above referenced statute and 49 C.F.R. § 190.239, a copy of which is enclosed. After evaluating the foregoing preliminary findings of fact and considering the location of the Failure site, the characteristics of the geographical areas where the pipeline is located, the safety related condition report submitted to PHMSA on August 23, 2019, which identified 33 features meeting Buckeye’s immediate repair condition criteria along the Affected Segment, indications that the Failure occurred at the site of a recent repair, the inability for Line 720’s leak detection system to detect the low-flow leak, the hazardous nature of the gasoline transported, the age of the pipe, and the ongoing investigation to determine the cause of the Failure, it appears that the continued operation of the Affected Segment, without corrective measures, poses a pipeline integrity risk to public safety, property, and the environment. Accordingly, PHMSA issues this Notice of Proposed Safety Order to notify Respondent of the proposed issuance of a safety order and to propose that Respondent take measures specified herein to address the potential risk Proposed Corrective Actions: Pursuant to 49 U.S.C. § 60117(l) and 49 C.F.R. § 190.239, PHMSA proposes to issue to Buckeye Corporation a safety order incorporating the following remedial requirements with respect to the Page 5 of 12#

120195012S_Notice of Proposed Safety Order_12052019_text.pdf, page 6Affected Segment and Isolated Segment: 1. 2. 3. 4. 5. 6. 7. Pressure Reduction. Buckeye shall maintain the existing operating pressure reduction for the Affected Segment of Line 720 that was initiated at the time of filing of the August 23, 2019 Safety Related Condition Report with PHMSA, which was based on 80% of the maximum pressure experienced in the 60 days prior to the ILI tool trap date from the July 12, 2019 assessment. Removal of Pressure Restriction. The Director may allow the removal or modification of the pressure restriction upon a written request from Respondent demonstrating that restoring the pipeline to its normal operating pressure is justified based on a reliable engineering analysis showing that the pressure increase is safe considering all known defects, anomalies, and operating parameters of the pipeline. The Director may also consider a demonstration that temporary mitigative and preventive measures are implemented prior to and during the temporary removal or modification of the pressure restriction. The Director's determination will be based on the cause of the failure and evidence of the analyses and measures taken. Review of Affected Segment. Buckeye must review and inspect the Affected Segment for conditions similar to those of the Failure or other Buckeye immediate conditions discovered, including a review of construction, operating and maintenance (O&M), and integrity management records such as in-line inspection (ILI) results, hydrostatic tests, root cause failure analysis of the Failure, aerial and ground patrols, cathodic protection, excavations and pipe replacements. Respondent must address any findings that require remedial measures to be implemented within 30 days of discovery. Enhanced surveillance and monitoring. Buckeye must provide for enhanced patrolling and surveillance of the Isolated Segment until the cause of the Failure is determined. Hydrostatic Testing. Buckeye must provide for hydrostatic pressure testing of any pipe installed in the Isolated Segment. Respondent must submit documentation of the testing of the installed pipe to the Director within 30 days of receipt of the final Safety Order. Records Verification. As recommended in PHMSA Advisory Bulletin 2012-06, Buckeye must verify the records for the Affected Segment to confirm the MOP. Buckeye must submit documentation of this record verification to the Director within 45 days of receipt of the final Safety Order. Review of Prior Inline Inspection (ILI) Results. Within 30 days of receipt of the final Safety Order, Buckeye must conduct a review of the previous five (5) inline inspection (ILI) run results of the Affected Segment. Buckeye must re-evaluate all ILI results, including a review of the ILI vendors' raw data and analysis. Buckeye must determine whether any features were present in the failed pipe joint and any other pipe removed. Also, Buckeye must determine if any features with similar characteristics are present Page 6 of 12#

120195012S_Notice of Proposed Safety Order_12052019_text.pdf, page 7elsewhere on the Affected Segment. Buckeye must submit documentation of this ILI review to the Director within 45 days of receipt of the final Safety Order as follows: A. List all ILI tool runs, tool types, and the calendar years of the tool runs. B. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI features present in the failed joint and/or other pipe removed. C. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI features with similar characteristics present elsewhere on the Affected Segment. D. Explain the process used to review the ILI results and the results of the reevaluation. 8. Mechanical and Metallurgical Testing. Within 45 days of receipt of the final Safety Order, Buckeye must arrange for third-party mechanical and metallurgical testing and failure analysis of the failed pipe, including an analysis of soil samples and any foreign materials. Buckeye must complete the testing and analysis as follows: A. Document the chain-of-custody when handling and transporting the failed pipe section and other evidence from the Failure site. B. Within 10 days of receipt of the final Safety Order, develop and submit the testing protocol and the proposed testing laboratory to the Director for prior approval. C. At least five days prior to beginning the mechanical and metallurgical testing, provide the Director with the scheduled date, time, and location of the testing to allow for a PHMSA representative to witness the testing. D. Ensure the testing laboratory distributes all reports whether draft or final in their entirety to the Director at the same time they are made available to Buckeye. 9. Root Cause Failure Analysis. Within 90 days following receipt of the final Safety Order, Buckeye must complete a root cause failure analysis (RCFA) and submit a final report of this RCFA to the Director. The RCFA must be supplemented and facilitated by an independent third party with prior written approval of the Director, and must document the decision-making process used in the analysis and all factors contributing to the Failure. The final report must include findings, any lessons learned, and whether the findings and any lessons learned are applicable to other locations within Buckeye pipeline system. 10. Remedial Work Plan. Within 90 days following receipt of the final Safety Order, Buckeye must submit a Remedial Work Plan (RWP) to the Director for approval. The Director may approve the RWP incrementally without approving the entire RWP. Buckeye must revise the RWP as necessary to incorporate new information obtained during the failure investigation and remedial activities, to incorporate the results of actions undertaken pursuant to the final Safety Order, and to incorporate modifications required by the Director. Buckeye must submit any such plan revisions to the Director for Page 7 of 12#

120195012S_Notice of Proposed Safety Order_12052019_text.pdf, page 8prior approval. The Director may approve plan revisions incrementally. Once approved by the Director, the RWP, and any revisions, will be incorporated by reference into the final Safety Order. Buckeye must implement the RWP as approved by the Director, including any revisions to the plan. The RWP must: A. Specify the tests, inspections, assessments, evaluations, and remedial measures Buckeye will use to verify the integrity of the Affected Segment. It must address all known or suspected factors and causes of the Failure. Buckeye should consider both the risk of another failure and the consequence of another failure to develop a prioritized schedule for RWP-related work along the Affected Segment. B. Include a procedure or process to identify pipe in the Affected Segment with characteristics similar to the contributing factors identified for the Failure. C. Include a procedure or process to gather all data necessary to review the failure history (in service and pressure test failures) of the Affected Segment and to prepare a written report containing all the available information such as the locations, dates, and causes of leaks and failures. D. Include a procedure or process to integrate the results of the metallurgical testing, RCFA, and other corrective actions required by the final Safety Order with all relevant pre-existing operational and assessment data for the Affected Segment. Pre- existing operational data includes, but is not limited to, construction, operations, maintenance, testing, repairs, prior metallurgical analyses, and any third-party consultation information. Pre-existing assessment data includes, but is not limited to, ILI tool runs, hydrostatic pressure testing, direct assessments, close interval surveys, and DCVG/ACVG surveys. E. Include a procedure or process to determine if conditions similar to those contributing to the Failure are likely to exist elsewhere on the Affected Segment. F. Include a procedure or process to conduct additional field tests, inspections, assessments, and/or evaluations to determine whether, and to what extent, the conditions associated with the Failure or any other integrity threats are present elsewhere on the Affected Segment. At a minimum, this process must consider all failure causes and specify the use of one or more of the following: i. Inline inspection (ILI) tools that are technically appropriate for assessing the pipeline system based on the cause of the Failure , and that can reliably detect and identify anomalies, ii. Hydrostatic pressure testing, iii. Close-interval surveys, iv. Cathodic protection surveys, to include interference surveys in coordination with other utilities (e.g. underground utilities, overhead power lines, etc.) in Page 8 of 12#

120195012S_Notice of Proposed Safety Order_12052019_text.pdf, page 9the area, v. Coating surveys, vi. Stress corrosion cracking surveys, vii. viii. Selective seam corrosion surveys; and, Other tests, inspections, assessments, and evaluations appropriate for the Failure causes. Note: Buckeye may use the results of previous tests, inspections, assessments, and evaluations if approved by the Director, provided the results of the tests, inspections, assessments, and evaluations are analyzed with regard to the factors known or suspected to have caused the Failure. G. Describe the inspection and repair criteria Buckeye will use to prioritize, excavate, evaluate, and repair anomalies, imperfections, and other identified integrity threats. Include a description of how any defects will be graded and a schedule for repairs or replacement. H. Based on the known history and condition of the Affected Segment, describe the methods Buckeye will use to repair, replace, or take other corrective measures to remediate the conditions associated with the Failure, and to address other known integrity threats along the Affected Segment. The repair, replacement, or other corrective measures must meet the criteria specified in paragraph G, above. I. Include a procedure or process to implement continuing long-term periodic testing and integrity verification measures to ensure the ongoing safe operation of the Affected Segment considering the results of the analyses, inspections, evaluations, and corrective measures undertaken pursuant to the final Safety Order. J. Include a proposed schedule for completion of the RWP. 11. Monthly Reports. Buckeye must submit monthly reports to the Director that: (1) include analysis of all available data and results of the testing and evaluations required by the final Safety Order; (2) describe the progress of repairs and other remedial actions being undertaken; and (3) document all mandated actions and management of change plans to ensure that all procedural modifications are incorporated into Buckeye’s operations and maintenance procedures manual. The first report will be due 30 days from issuance of the final Safety Order. 12. Safety Order Documentation Report (SODR). When Buckeye has completed all the items in the final Safety Order it will submit a final SODR in its entirety to the Director. This will allow the Director to conduct a thorough review of all actions taken by Buckeye with regards to the final Safety Order prior to approving the closure of the final Safety Order. The intent is for the SODR to summarize all activities and documentation associated with the final Safety Order in one document. Page 9 of 12#

120195012S_Notice of Proposed Safety Order_12052019_text.pdf, page 10A. The Director may approve the SODR incrementally without approving the entire SODR. B. Once approved by the Director, the SODR will be incorporated by reference into the final Safety Order. C. The SODR must include but is not limited to: 1. Table of Contents; 2. Summary of the Failure, and the response activities; 3. Summary of pipe data/properties and all prior assessments of the Affected Segment; 4. Summary of all tests, inspections, assessments, evaluations, and analysis required by the final Safety Order; 5. Summary of the Mechanical and Metallurgical Testing as required by the final Safety Order; 6. Summary of the RCFA with all root causes as required by the final Safety Order; 7. Documentation of all actions taken by Buckeye to implement the RWP, the results of those actions, and the inspection and repair criteria used; 8. Documentation of any revisions to the RWP including those necessary to incorporate the results of actions undertaken pursuant to the final Safety Order and whenever necessary to incorporate new information obtained during the failure investigation and remedial activities; 9. Lessons learned while completing the final Safety Order; 10. A path forward describing specific actions Buckeye will take on its entire pipeline system as a result of the lessons learned from work on the final Safety Order; and 11. Appendices (if required). With respect to each submission under the final Safety Order that requires the approval of the Director, the Director may: (a) approve, in whole or part, the submission; (b) approve the submission on specified conditions; (c) modify the submission to cure any deficiencies; (d) disapprove, in whole or in part, the submission, directing that Respondent modify the submission; or (e) any combination of the above. In the event of approval, approval upon conditions, or modification by the Director, Respondent shall take all required actions in the submission as approved or modified by the Director. If the Director disapproves all or any portion of the submission, Respondent shall correct all deficiencies within the time specified by the Director, and resubmit it for approval. If a resubmitted item is disapproved in whole or in part, the Director may again require Respondent to correct the deficiencies in accordance with the foregoing procedure, and the Director may otherwise proceed to enforce the terms of the final Safety Order. Page 10 of 12#

120195012S_Notice of Proposed Safety Order_12052019_text.pdf, page 11The Director may grant an extension of time for compliance with any of the terms of the final Safety Order upon a written request timely submitted demonstrating good cause for an extension. Buckeye may appeal any decision of the Director to the Associate Administrator for Pipeline Safety. Decisions of the Associate Administrator shall be final. The actions proposed by this Notice are in addition to and do not waive any requirements that apply to Respondent's pipeline system under 49 C.F.R. Parts 190 through 199, under any other order issued to Respondent under authority of 49 U.S.C. § 60101 et seq., or under any other provision of Federal or state law. After receiving and analyzing additional data in the course of this investigation, PHMSA may identify other corrective measures that need to be taken. In that event, Respondent will be notified of any additional measures required and amendment of the final Safety Order will be considered. To the extent consistent with safety, Respondent will be afforded notice and an opportunity for a hearing prior to the imposition of any additional corrective measures. Response to this Notice: In accordance with § 190.239, you have 30 days following receipt of this Notice to submit a written response to the Director. If you do not respond within 30 days, this constitutes a waiver of your rights to contest 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 Safety Order. In your response, you may indicate that you intend to comply with the terms of the Notice as proposed, or you may request that an informal consultation be scheduled (you will also have the opportunity to request an administrative hearing before a final Safety Order is issued). Informal consultation provides you with an opportunity to explain the circumstances associated with the risk conditions alleged in the Notice and, as appropriate, to present a proposal for a work plan or other remedial measures, without prejudice to your position in any subsequent hearing. If you and PHMSA agree within 30 days of informal consultation on a plan and schedule for you to address each identified risk condition, the parties may enter into a written consent agreement, in which case PHMSA would then issue an administrative Consent Order incorporating the terms of the agreement. If a consent agreement is not reached, or if you have elected not to request informal consultation, you may request an administrative hearing in writing within 30 days following receipt of the Notice or within 10 days following the conclusion of an informal consultation that did not result in a consent agreement, as applicable. Following a hearing, if the Associate Administrator finds the facility to have a condition that poses a pipeline integrity risk to the public, property, or the environment in accordance with § 190.239, the Associate Administrator may issue a final Safety Order. Be advised that all material submitted in response to this enforcement action is subject to public availability. 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). In your correspondence on this matter, please refer to CPF No. 1-2019-5012S and for each Page 11 of 12#

120195012S_Notice of Proposed Safety Order_12052019_text.pdf, page 12document you submit, please provide a copy in electronic format whenever possible. _________________________________ _____________________ Robert Burrough Date issued Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Page 12 of 12#

120195012S_Closure Letter_05282021_(19-168035S)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: csmith@buckeye.com May 28, 2021 Mr. Clark C. Smith President and Chief Executive Officer Buckeye Partners, LP One Greenway Plaza, Suite 600 Houston, Texas 77046 CPF 1-2019-5012S Dear Mr. Smith: On April 27, 2020, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Buckeye Partners, LP’s (Buckeye) a Consent Agreement and Order in the above-referenced case. This Order included a requirement to take corrective actions on your pipeline. Based on our review of the documentation you provided, 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 cc: Mr. William Hollis, Senior Vice President, Buckeye Partners, LP, whollis@buckeye.com Ms. Claudia Pankowski, Director of Regulatory Compliance, Buckeye Partners, LP, cpankowski@buckeye.com#