# BUCKEYE PARTNERS, LP — Corrective Action Order

- **operation:** document
- **citation:** CPF 12021034CAO
- **title:** BUCKEYE PARTNERS, LP — Corrective Action Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2021-03-19
- **effective on:** Not available
- **summary:** CLOSED corrective action order.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-12021034cao.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-12021034cao.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-12021034cao
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12021034CAO
**body:**

Corrective Action Order involving BUCKEYE PARTNERS, LP. The dataset does not identify a cited regulation for this case. The case was opened on 2021-03-19 and is reported as closed as of 2023-07-13. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12021034CAO_Amended Corrective Action Order_05042021_(21-207810).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021034CAO/12021034CAO_Amended%20Corrective%20Action%20Order_05042021_(21-207810).pdf

12021034CAO_Amended Corrective Action Order_05042021_(21-207810)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021034CAO/12021034CAO_Amended%20Corrective%20Action%20Order_05042021_(21-207810)_text.pdf

12021034CAO_Closure Letter_07132023_(21-207810).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021034CAO/12021034CAO_Closure%20Letter_07132023_(21-207810).pdf

12021034CAO_Closure Letter_07132023_(21-207810)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021034CAO/12021034CAO_Closure%20Letter_07132023_(21-207810)_text.pdf

12021034CAO_Corrective Action Order_03192021_(21-207810).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021034CAO/12021034CAO_Corrective%20Action%20Order_03192021_(21-207810).pdf

12021034CAO_Corrective Action Order_03192021_(21-207810)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021034CAO/12021034CAO_Corrective%20Action%20Order_03192021_(21-207810)_text.pdf

12021034CAO_Op Req for Hearing and Req Time Extension_03292021_(21-207810).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021034CAO/12021034CAO_Op%20Req%20for%20Hearing%20and%20Req%20Time%20Extension_03292021_(21-207810).pdf

12021034CAO_Operator Hearing Request Withdrawn_04062021_(21-207810).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12021034CAO/12021034CAO_Operator%20Hearing%20Request%20Withdrawn_04062021_(21-207810).pdf

12021034CAO_Closure Letter_07132023_(21-207810)_text.pdf

OVERNIGHT EXPRESS DELIVERY
July 13, 2023
Mr. Todd Russo
Chief Executive Officer
Buckeye Partners, LP
4200 Westheimer Road
Suite 975
Houston, Texas 77027
CPF 1-2021-034-CAO
Dear Mr. Russo:
On March 19, 2021, and on May 4, 2021, the Pipeline and Hazardous Materials Safety
Administration (PHMSA) issued a Corrective Action Order (CAO) and an Amended Corrective
Action Order (ACAO), respectively, to Buckeye Partners, LP (Buckeye), with regard to the March
16, 2021 rupture of its 12-inch hazardous liquid pipeline located in Linden, New Jersey. The
ACAO included a list of various required Corrective Actions.
We have received the CAO Documentation Report (CDR), dated February 2, 2023, from Ms.
Claudia Pankowski, Director of Regulatory Compliance. We have also received quarterly reports,
monthly reports, and other information.
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 CAO is now closed. Thank you for your
cooperation in this matter.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration



Cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS,
PHMSA <linda.daugherty@dot.gov>
Ms. Claudia Pankowski, Director of Regulatory Compliance, Buckeye Partners, LP
<cpankowski@buckeye.com>
Mr. Evan Hofmann, General Counsel, Buckeye Partners, LP <ehofmann@buckeye.com>

12021034CAO_Amended Corrective Action Order_05042021_(21-207810)_text.pdf

May 4, 2021
VIA ELECTRONIC MAIL TO: csmith@buckeye.com
Mr. Clark C. Smith
President and Chief Executive Officer
Buckeye Partners, LP
One Greenway Plaza, Suite 600
Houston, Texas 77046
CPF No. 1-2021-034-CAO
Dear Mr. Smith:
Enclosed please find an Amended Corrective Action Order issued by the Pipeline and Hazardous
Materials Safety Administration, Office of Pipeline Safety, in the above-referenced case. It
requires Buckeye Partners, LP to take certain corrective actions with respect to the March 16,
2021 failure of Line 602, a 12-inch transmission line, in Linden, New Jersey.
Service of the Amended Corrective Action Order by e-mail is deemed complete upon
transmission and acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5.
The terms and conditions of this Order are effective upon completion of service.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure: Amended Corrective Action Order
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Mr. Robert Burrough, Director, Eastern Region, OPS
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
CONFIRMATION OF RECEIPT REQUESTED



U.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,
)
)
)
)
)
Respondent.
____________________________________)
CPF No. 1-2021-034-CAO
AMENDED CORRECTIVE ACTION ORDER
Purpose and Background
This Amended Corrective Action Order (ACAO or Amended Order) is being issued by the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), under the authority of 49 U.S.C. § 60112 to require Buckeye Partners, LP (Buckeye or
Respondent) to take the necessary corrective actions to protect the public, property, and the
environment from potential hazards associated with the March 16, 2021 rupture of its 12-inch
hazardous liquid pipeline located in Linden, New Jersey: the “Accident.”
At approximately 5:26 AM ET, on March 16, 2021, Buckeye’s 12-inch hazardous liquid
pipeline, Line 602, ruptured and released approximately 353 barrels of unleaded gasoline in
Linden, New Jersey. The accident was discovered when Buckeye’s supervisory control and data
acquisition (SCADA) control center in Breinigsville, Pennsylvania indicated that the flow rate
was continuing to rise while the pressure plateaued. Buckeye’s system automatically shut down
the pipeline due to a low inlet pump pressure safety switch. Buckeye controllers followed-up by
having field personnel close remote block valves, and dispatched personnel to locate the failure.
Buckeye personnel discovered gasoline in a low-lying swamp between mile post (MP) 99+98
and MP 109+89, near the Arthur Kill River.
Buckeye deployed an oil spill response team to the site to run a containment and absorbent boom
to keep the release from reaching a tributary of the Arthur Kill River. The two remote block
valves Buckeye closed were at the west bank of the Arthur Kill River, north of the release site,
and at the south side of the site. There were no reports of fires, injuries, fatalities or evacuations.
Pursuant to 49 U.S.C. § 60117, PHMSA initiated an investigation of the Accident, and on March
19, 2021, issued a Corrective Action Order (CAO). However, as a result of PHMSA’s continued
investigation and additional information provided by Buckeye, PHMSA is issuing this ACAO to
modify a definition, modify corrective actions based upon a technical review of data submitted
by Buckeye, and grant extensions of time for completion of some of the corrective actions. The



CPF No. 1-2021-034-CAO
Page 2
ACAO does not make any substantive changes to the corrective actions prescribed in the CAO.
The amended preliminary findings of the agency’s ongoing investigation are as follows:
Amended Preliminary Findings
 At approximately 5:26 AM ET, on March 16, 2021, Buckeye’s 12-inch hazardous
liquid pipeline, Line 602, ruptured and the line was automatically shut down by a low
inlet pump pressure safety switch. Buckeye’s SCADA control center in Breinigsville,
Pennsylvania, later identified that the flow rate on Line 602 was rising but the
pressure had plateaued. Buckeye’s control center requested that Linden station
personnel keep Line 602 shutdown; closed block valves located at Valve Site 1L-
Linden Station, stationing (Sta.) 3+72, and Valve Site 2L-West Side Arthur Kill, Sta.
130+30; and dispatched personnel to determine the cause for the plateau. Buckeye
personnel discovered gasoline bubbling up in a low-lying swamp between mile post
(MP) 99+98 and MP 109+89, near the Arthur Kill River.
 Buckeye reported the Accident to the National Response Center (NRC) at 8:40 AM
ET on March 16, 2021, (NRC Report No. 1300418), indicating it released an
estimated 55 barrels of unleaded gasoline into swampland near the Arthur Kill River.
Later in the afternoon, at 3:35 PM ET, Buckeye revised its release estimate to
approximately 353 barrels of unleaded gasoline.
 There were no fires, injuries, fatalities, or evacuations associated with the Accident.
 Prior to the rupture, the operating pressure on Line 602 was 1145 pounds per square
in gauge (psig). The maximum operating pressure (MOP) of the line is 1222 psig.
 Line 602 is a 12-inch nominal diameter, 0.25-inch wall thickness, API 5L, X-60
grade, seamless pipe that was constructed in 1965. It has a coal tar coating and an
impressed current cathodic protection system. Line 602 is one of five parallel
pipelines in the right-of-way (ROW). There are two Buckeye pipelines (Line 601 and
Line 602) and three Colonial pipelines in the ROW at the failure location. Both Lines
601 and 602 run from the Linden, New Jersey terminal to New Lots Junction in New
York. Line 601 then travels to John F. Kennedy and LaGuardia airports. Line 602
travels to Long Island City, New York and Inwood, New York. Another Buckeye
pipeline, Line 607, runs from the Linden, New Jersey terminal and supplies jet fuel to
Newark Liberty airport.
 The Respondent performed an in-line inspection (ILI) on Line 602, utilizing both a
geometry and magnetic flux leakage (MFL) tool in July 2019. Multiple general metal
loss and pitting anomalies were identified, but Buckeye reports the anomalies were
not of a degree that were actionable. Respondent’s two pipelines (601 and 602) are
both located in similar, marshy environments.



CPF No. 1-2021-034-CAO
Page 3
 Buckeye shut in Line 601 during the post-failure excavation activities on Line 602.
The closest Colonial pipeline in the ROW is idle and was previously purged with
nitrogen. The remaining two Colonial pipelines contain hazardous liquids but are
currently idle due to lack of demand.
 Respondent’s Lines 602 and 601 are pipeline facilities subject to the pipeline safety
laws in 49 U.S.C. chapter 601 and 49 C.F.R. part 195.
 The Buckeye pipeline system in the Linden Area of New Jersey consists of: 20-inch
and 16-inch pipelines from Linden, New Jersey to Pennsylvania (49.1 miles); a 12-
inch pipeline from Sewaren, New Jersey to Linden Station (5.2 miles); a 6-inch
pipeline from Linden, New Jersey (1 mile) that turns into an 8-inch pipeline to
Newark airport (6.1 miles)(Line 607); two 12-inch pipelines from Linden, New
Jersey to Long Island, New York (2.8 miles)(Lines 601 and 602); 49 breakout tanks
located at the Linden facility; one breakout tank located at Newark airport; and one
pump station at the Linden facility. The Linden Area system includes several river
crossings.
 The failure occurred in a high-consequence area, near a commercially navigable
waterway – the Arthur Kill River - approximately 2.5 miles east of Linden, New
Jersey. Line 602 traverses several high consequence areas.
 Preliminary indications suggest the Accident occurred due to thinning of pipe wall
because of generalized corrosion at the 3 o’clock position along the longitudinal axis.
 The Isolated Segment (defined below) was cut out and replaced with pretested pipe
on March 21, 2021, pursuant to the terms of the CAO.
 Pursuant to the terms of the CAO, Buckeye submitted a written Restart Plan to the
Director on March 21, 2021. The Restart Plan was approved by the Director on
March 24, 2021.
 The Isolated Segment was restarted at 60% of MOP on March 25, 2021, pursuant to
the terms of the Restart Plan.
On March 30, 2021, Buckeye submitted technical data on Line 607, which included material
specifications, date of installation, and inspection reports. Based upon a review of this data, Line
607 differs significantly from Lines 601 and 602 in material, installation, and operating
conditions. For this reason, we are removing Line 607 from the scope of the ACAO.
Determination of Necessity for Corrective Action Order and Right to Hearing
Section 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline
facility is or would be hazardous to life, property, or the environment and if there is a likelihood
of serious harm, to expeditiously order the operator of the facility to take necessary corrective
action, including suspended or restricted use of the facility, physical inspection, testing, repair,



CPF No. 1-2021-034-CAO
Page 4
replacement, or other appropriate action. An order issued expeditiously must provide an
opportunity for a hearing as soon as practicable after the order is issued.
In deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the
characteristics of the pipe and other equipment used in the pipeline facility, including the age,
manufacture, physical properties, and method of manufacturing, constructing, or assembling the
equipment; (2) the nature of the material the pipeline facility transports, the corrosive and
deteriorative qualities of the material, the sequence in which the material is transported, and the
pressure required for transporting the material; (3) the aspects of the area in which the pipeline
facility is located, including climatic and geologic conditions and soil characteristics; (4) the
proximity of the area in which the hazardous liquid pipeline facility is located to environmentally
sensitive areas; (5) the population density and population and growth patterns of the area in
which the pipeline facility is located; (6) any recommendation of the National Transportation
Safety Board made under another law; and (7) any other factors PHMSA may consider as
appropriate.
After evaluating the amended preliminary findings of fact, and having considered the age of the
pipeline, the hazardous nature of the materials transported, the July 2019 ILI on Line 602 that
failed to detect corrosion preliminarily observed at the failure site, the location of the spill in a
low-lying marsh near a navigable body of water, and the likelihood that similar conditions
conducive to corrosion exist on Buckeye's other pipelines in the Linden Area pipeline system, I
find that continued operation of the Affected Pipelines, as defined below, without corrective
measures is or would be hazardous to life, property, or the environment, and that failure to issue
this Amended Order expeditiously would result in the likelihood of serious harm.
Accordingly, this Amended Order mandating immediate corrective action is issued expeditiously
without prior notice and opportunity for a hearing. The terms and conditions of this Amended
Order are effective upon receipt.
Within 10 days of receipt of this Amended Order, Respondent may request a hearing, to be held
as soon as practicable, by notifying the Associate Administrator for Pipeline Safety in writing,
with a copy to the Director, Eastern Region, PHMSA. If a hearing is requested, it will be held in
accordance with 49 C.F.R. § 190.211.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective measures that need to be taken. Respondent will be notified of any
additional measures required and, if appropriate, a further amended order will be issued. 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.
Required Corrective Actions
Definitions:
Affected Pipelines – The “Affected Pipelines” means Buckeye’s 12-inch Line 602 and
Buckeye’s 12-inch Line 601, both located in Linden, New Jersey.



CPF No. 1-2021-034-CAO
Page 5
Isolated Segment – The "Isolated Segment" means Buckeye’s Line 602 between the valve at
Valve Site 1L - Linden Station (Sta 3+72) and the valve at Valve Site 2L – West Side Arthur
Kill (Sta 130+30).
Director – The Director, Eastern Region, PHMSA, OPS, 840 Bear Tavern Rd., Ste. 300,
West. Trenton, New Jersey 08628.
Day – Calendar day.
Pursuant to 49 U.S.C. 60112, I hereby order Respondent to immediately take the following
corrective actions:
1. Shutdown of the Isolated Segment. The Isolated Segment was out of service from March
16, 2021 through March 24, 2021. The Isolated Segment remained shut-in and was not
operated until authorized to restart by the Director on March 24, 2021, in accordance with
the terms of the CAO.
2. Operating Pressure Restriction. Buckeye must maintain a forty percent (40%) pressure
reduction in the maximum operating pressure (MOP) along the entire length of the Isolated
Segment, and must maintain a twenty percent (20%) pressure reduction along the remaining
length of the Affected Pipelines, such that the operating pressure will not exceed eighty
percent (80%) of the MOP.
a. This pressure restriction is to remain in effect until written approval to increase the
pressure or return a pipeline to its pre-failure operating pressure is obtained from the
Director.
3. b. On March 19, 2021, Respondent provided the Director the actual operating pressures of
each pump station on the Affected Pipelines at the time of failure and the reduced
pressure restriction set-points at these same locations.
c. This pressure restriction requires any relevant remote or local alarm limits, software
programming set-points or control points, and mechanical over-pressure devices to be
adjusted accordingly.
d. When determining the pressure restriction set-points, Respondent must take into
account any ILI features or anomalies present in the Affected Pipelines to provide for
continued safe operation while further corrective actions are completed.
e. Respondent must review the pressure restriction monthly by analyzing the operating
pressure data, taking into account any ILI features or anomalies present in the Affected
Pipelines. Respondent must immediately reduce the operating pressure further to
maintain the safe operations of the Affected Pipelines, if warranted by the monthly
review. Respondent must submit the results of the monthly review to the Director
including, at a minimum, the current discharge set-points (including any additional
pressure reductions), and any pressure exceedance at discharge set-points. Submittals
must be made quarterly, in accordance with Item 17 below.
Restart Plan. Pursuant to the terms of the CAO, Buckeye developed and submitted a
written Restart Plan to the Director on March 21, 2021. The Director approved the Restart



CPF No. 1-2021-034-CAO
Page 6
Plan on March 24, 2021. The Restart Plan is incorporated by reference in to this Amended
4. 5. 6. 7. Order.
Return to Service. Pursuant to the terms of the CAO and the approved Restart Plan,
Respondent returned the Isolated Segment to service on March 25, 2021. The operating
pressure must not exceed the pressure restrictions in accordance with Item 2 above.
Removal or Modification of Pressure Restriction.
a. The Director may allow the removal or modification of the pressure restriction upon a
written request from Respondent demonstrating that modifying or restoring the
Affected Pipelines to their pre-failure operating pressures 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.
b. The Director may allow the temporary removal or modification of the pressure
restrictions upon a written request from Respondent demonstrating 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 failure cause and provision of evidence that
preventative and mitigative actions taken by the operator provide for the safe
operation of the Affected Pipelines during the temporary removal or modification of
the pressure restriction. Appeals to determinations of the Director in this regard will
be decided by the Associate Administrator for Pipeline Safety.
Mechanical and Metallurgical Testing. By May 18, 2021, Respondent must complete
mechanical and metallurgical testing and failure analysis of the failed pipe, including an
analysis of soil samples and any foreign materials. Mechanical and metallurgical testing
must be conducted by an independent third-party acceptable to the Director, and must
document the decision-making process and all factors contributing to the failure.
Respondent must complete the testing and analysis as follows:
a. Buckeye provided chain-of-custody documentation for the handling and transporting
of the failed pipe section and evidence from the failure site on March 30, 2021.
b. Pursuant to the CAO, the Respondent developed and submitted the testing protocol
and the proposed testing laboratory to the Director for approval on March 19, 2021.
The Director approved the testing protocol on March 19, 2021.
c. Prior to beginning the mechanical and metallurgical testing, provide the Director with
the scheduled date, time, and location of the testing to allow for an OPS
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 Respondent.
Root Cause Failure Analysis. By July 17, 2021, Respondent must complete a root cause
failure analysis (RCFA) and submit a final report of this RCFA to the Director. The RCFA
must be supplemented or facilitated by an independent third-party acceptable to the
Director and must document the decision-making process and all factors contributing to the
failure. The final report must include findings and any lessons learned and whether the



CPF No. 1-2021-034-CAO
Page 7
findings and lessons learned are applicable to other locations within Respondent’s pipeline
system.
8. Remedial Work Plan (RWP).
a. b. c. d. e. Within 30 days following the completion of the RCFA, see Item 7 above, Respondent
must submit a Remedial Work Plan (RWP) to the Director for approval.
The Director may approve the RWP incrementally without approving the entire RWP.
Once approved by the Director, the RWP will be incorporated by reference into this
Amended Order.
The RWP must specify the tests, inspections, assessments, evaluations, and remedial
measures Respondent will use to verify the integrity of the Affected Pipelines. It must
address all known or suspected factors and causes of the Accident. Respondent must
consider the risks and consequences of another failure to develop a prioritized
schedule for RWP-related work along the Affected Pipelines.
The RWP must include a procedure or process to:
i. Identify pipe in the Affected Pipelines with characteristics similar to the
contributing factors identified for the Accident.
ii. Gather all data necessary to review the failure history (in service and pressure test
failures) of the Affected Pipelines and to prepare a written report containing all the
available information such as the locations, dates, and causes of leaks and
failures.
iii. iv. v. Integrate the results of the metallurgical testing, root cause failure analysis, and
other corrective actions required by this Amended Order with all relevant pre-
existing operational and assessment data for the Affected Pipelines. Pre-existing
operational data includes, but is not limited to, design, 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.
Determine if conditions similar to those contributing to the Accident are likely to
exist elsewhere on the Affected Pipelines.
Conduct additional field tests, inspections, assessments, and evaluations to
determine whether, and to what extent, the conditions associated with the
Accident and other failures from the failure history (see (e)(ii) above) or any other
integrity threats are present elsewhere on the Affected Pipelines. At a minimum,
this process must consider all failure causes and use:
1) ILI tools with ultrasonic thickness (UT) measurement technology, and
ACVG/DCVG surveys to detect holidays under disbonded coating; and one or
more of the following, if necessary:
2) Hydrostatic pressure testing;
3) Close-interval surveys;



CPF No. 1-2021-034-CAO
Page 8
9. 4) Cathodic protection surveys, to include interference surveys in coordination
with other utilities (e.g. underground utilities, overhead power lines, etc.) in
the area;
5) Coating surveys;
6) Stress corrosion cracking surveys;
7) Selective seam corrosion surveys; and
8) Other tests, inspections, assessments, and evaluations appropriate for the
failure causes.
Note: The results of tests, inspections, assessments, and evaluations conducted prior
to issuance of this CAO may be used only if they included UT measurement
technology.
vi. Describe the inspection and repair criteria Respondent 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.
vii. Based on the known history and condition of the Affected Pipelines, describe the
methods Respondent will use to repair, replace, or take other corrective measures
to remediate the conditions associated with the Accident and to address other
known integrity threats along the Affected Pipelines. The repair, replacement, or
other corrective measures must meet the criteria specified in (e)(vi) above.
viii. Implement continuing long-term periodic testing and integrity verification
measures to ensure the ongoing safe operation of the Affected Pipelines
considering the results of the analyses, inspections, evaluations, and corrective
measures undertaken pursuant to the Amended Order.
f. g. Include a proposed schedule for completion of the RWP.
Respondent 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 Amended Order, and to incorporate modifications
required by the Director.
h. Submit any plan revisions to the Director for prior approval.
i. The Director may approve plan revisions incrementally.
ii. All revisions to the RWP after it has been approved and incorporated by reference
into this Amended Order will be fully described and documented in the CAO
Documentation Report, see below.
i. Implement the RWP as it is approved by the Director, including any revisions to the
plan.
Patrolling. Within 30 days of receipt of this Amended Order, Respondent must perform an
aerial or ground right-of-way patrol of the Affected Pipelines. Respondent must investigate
all leak indications and remedy all leaks discovered. Respondent must submit
documentation of this survey to the Director within 45 days of receipt of this Amended
Order.



CPF No. 1-2021-034-CAO
Page 9
10. Records Verification. As outlined in PHMSA Advisory Bulletin 2012-06, Respondent
must verify the records for the Affected Pipelines to confirm the MOP. Respondent must
submit documentation of this this record verification to the Director within 45 days of
receipt of this Amended Order.
11. Review of Prior Inline Inspection (ILI) Results. By May 7, 2021, Respondent must
conduct a review of any previous ILI results of the Affected Pipelines. In its review,
Respondent must re-evaluate all ILI results from the past 10 calendar years, including a
review of the ILI vendor’s raw data and analysis. Respondent must determine whether any
features were present in the failed pipe joints from the Accident and any other pipe
removed. Respondent must also determine if any features with similar characteristics are
present elsewhere on the Affected Pipelines. Respondent must submit documentation of
this ILI review to the Director within 30 days of receipt of this Amended Order as follows:
a. b. List all ILI tool runs, tool types, and the calendar years of the tool runs.
List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI
features present in the failed joint and 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 Pipelines.
d. Explain the process used to review the ILI results and the results of the reevaluation.
12. Emergency Response Plan and Training Review. Respondent must review and assess the
effectiveness of its emergency response plan with regards to the failure. Include in the
review and assessment the on-scene response and support, coordination, and
communication with emergency responders and public officials. Also, include a review
and assessment of the effectiveness of its emergency training program. Respondent must
amend its emergency response plan and emergency training, if necessary, to reflect the
results of this review. Further, Respondent must review controller response to all alarms
prior to, and following, confirmation of the rupture. Respondent must also review the
controllers’ coordination and communications with internal and external stakeholders prior
to and throughout this accident response. The documentation of this Emergency Response
Plan and Training Review must be available for inspection by OPS or provided to the
Director, if requested.
13. Public Awareness Program Review. Respondent must review and assess the effectiveness
of its Public Awareness Program with regards to the failure. Respondent must amend its
Public Awareness Program, if necessary, to reflect the results of this review. The
documentation of this Public Awareness Program Review must be available for inspection
by OPS or provided to the Director, if requested.
14. CAO Documentation Report (CDR). Respondent must create and revise, as necessary, a
CAO Documentation Report (CDR). When Respondent has concluded all the items in this
Amended Order it will submit the final CDR in its entirety to the Director. This will allow
the Director to complete a thorough review of all actions taken by Respondent with regards
to this Amended Order prior to approving its closure. The intent is for the CDR to
summarize all activities and documentation associated with this Amended Order in one
document.



CPF No. 1-2021-034-CAO
Page 10
a. b. c. The Director may approve the CDR incrementally without approving the entire CDR.
Once approved by the Director, the CDR will be incorporated by reference into this
Amended Order.
The CDR must include, but is not necessarily limited to, the following:
i. Table of Contents;
ii. iii. Summary of the Accident and the response activities;
Summary of pipe data, material properties and all prior assessments of the
Affected Pipeline;
iv. Summary of all tests, inspections, assessments, evaluations, and analysis required
by the Amended Order;
v. Summary of the mechanical and metallurgical testing as required by the Amended
Order;
vi. vii. Summary of the RCFA with all root causes as required by the Amended Order;
Documentation of all actions taken by Respondent 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 Amended Order and
whenever necessary to incorporate new information obtained during the failure
investigation and remedial activities;
ix. x. Lessons learned while completing this Amended Order;
A path forward describing specific actions Respondent will take on its entire
pipeline system as a result of the lessons learned from work on this Amended
Order; and
xi. Appendices (if required).
Other Requirements:
15. Approvals. With respect to each submission that under this Amended 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
proceed to take all action required by the submission as approved or modified by the
Director. If the Director disapproves all or any portion of the submission, Respondent must
correct all deficiencies within the time specified by the Director, and resubmit it for
approval.
16. Extensions of Time. The Director may grant an extension of time for compliance with any
of the terms of this Amended Order upon a written request timely submitted demonstrating
good cause for an extension.



CPF No. 1-2021-034-CAO
Page 11
17. Reporting. Respondent must submit quarterly reports to the Director that: (1) include all
available data and results of the testing and evaluations required by this Amended Order;
and (2) describe the progress of the repairs or other remedial actions being undertaken.
The first quarterly report is due on June 18, 2021. The Director may change the interval for
the submission of these reports.
18. Documentation of the Costs. It is requested but not required that Respondent maintain
documentation of the costs associated with implementation of this ACAO. Include in each
monthly report submitted, the to-date total costs associated with: (1) preparation and
revision of procedures, studies, and analyses; (2) physical changes to pipeline
infrastructure, including repairs, replacements, and other modifications; and (3)
environmental remediation, if applicable.
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).
In your correspondence on this matter, please refer to “CPF No. 1-2021-034-CAO” and for each
document you submit, please provide a copy in electronic format whenever possible. The
actions required by this Amended Order 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. Chapter 601, or under any other
provision of Federal or State law.
Respondent may appeal in writing any decision of the Director to the Associate Administrator
for Pipeline Safety. Decisions of the Associate Administrator shall be final.
Failure to comply with this Amended Order may result in the assessment of civil penalties and in
referral to the Attorney General for appropriate relief in United States District Court pursuant to
49 U.S.C. § 60120.
The terms and conditions of this Amended Order are effective upon service in accordance with
49 C.F.R. § 190.5.
May 4, 2021
_________________________________ ________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

12021034CAO_Corrective Action Order_03192021_(21-207810)_text.pdf

March 19, 2021
VIA ELECTRONIC MAIL TO: csmith@buckeye.com
Mr. Clark C. Smith
President and Chief Executive Officer
Buckeye Partners, LP
One Greenway Plaza, Suite 600
Houston, Texas 77046
CPF No. 1-2021-034-CAO
Dear Mr. Smith:
Enclosed please find a Corrective Action Order (CAO or Order) issued by the Pipeline and
Hazardous Materials Safety Administration, Office of Pipeline Safety, in the above-referenced
case. It requires Buckeye Partners, LP (Buckeye or Respondent) to take certain corrective
actions with respect to the March 16, 2021 failure of Line 602, a 12-inch transmission line, in
Linden, New Jersey.
Service of the CAO by e-mail is deemed complete upon transmission and acknowledgement of
receipt, or as otherwise provided under 49 C.F.R. § 190.5. The terms and conditions of this
Order are effective upon completion of service.
Sincerely,
Alan Mayberry
Associate Administrator
for Pipeline Safety
Enclosure: CAO
cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS
Mr. Robert Burrough, Director, Eastern Region, OPS
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
CONFIRMATION OF RECEIPT REQUESTED



U.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,
)
)
)
)
)
Respondent.
____________________________________)
CPF No. 1-2021-034-CAO
CORRECTIVE ACTION ORDER
Purpose and Background
This Corrective Action Order (CAO or Order) is being issued by the Pipeline and Hazardous
Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), under the authority
of 49 U.S.C. § 60112 to require Buckeye Partners, LP (Buckeye or Respondent) to take the
necessary corrective actions to protect the public, property, and the environment from potential
hazards associated with the March 16, 2021 rupture of its 12-inch hazardous liquid pipeline
located in Linden, New Jersey (Accident).
At approximately 5:26 AM ET, on March 16, 2021, Buckeye’s 12-inch hazardous liquid
pipeline, Line 602, ruptured and released approximately 353 barrels of unleaded gasoline in
Linden, New Jersey. The accident was discovered when Buckeye’s supervisory control and data
acquisition (SCADA) control center in Breinigsville, Pennsylvania indicated that the flow rate
was continuing rise while the pressure plateaued. Buckeye shut down the pipeline, closed
remote block valves, and dispatched personnel to the site. Buckeye personnel discovered
gasoline bubbling up in a low-lying swamp between mile post (MP) 99+98 and MP 109+89, near
the Arthur Kill River.
Buckeye deployed an oil spill response team to the site to run a containment and absorbent boom
to keep the release from reaching the tributary or the Arthur Kill River. The two remote block
valves Buckeye closed were at the west bank of the Arthur Kill River, north of the release site,
and at the south side of the site. There were no reports of fires, injuries, fatalities or evacuations.
Pursuant to 49 U.S.C. § 60117, PHMSA initiated an investigation of the Accident. The
preliminary findings of the agency’s ongoing investigation are as follows:
Preliminary Findings
 At approximately 5:26 AM ET, on March 16, 2021, Buckeye’s 12-inch hazardous
liquid pipeline, Line 602, ruptured. Buckeye’s SCADA control center in



CPF No. 1-2021-034-CAO
Page 2
Breinigsville, Pennsylvania, detected that the flow rate on Line 602 was rising but the
pressure had plateaued. Buckeye’s control center remotely shut down Line 602;
closed block valves located at Valve Site 1L-Linden Station, stationing (Sta.) 3+72,
and Valve Site 2L-West Side Arthur Kill, Sta. 130+30; and dispatched personnel to
determine the cause for the plateau. Buck
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