BUCKEYE PARTNERS, LP — Corrective Action Order

case documentOfficial PDF12021034CAO_Op Req for Hearing and Req Time Extension_03292021_(21-207810).pdf#

party submissionOfficial PDF12021034CAO_Operator Hearing Request Withdrawn_04062021_(21-207810).pdf#

12021034CAO_Closure Letter_07132023_(21-207810)_text.pdf, page 1Official PDFOVERNIGHT 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#

12021034CAO_Closure Letter_07132023_(21-207810)_text.pdf, page 2Cc: 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, page 1Official PDFMay 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#

12021034CAO_Amended Corrective Action Order_05042021_(21-207810)_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, ) ) ) ) ) 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#

12021034CAO_Amended Corrective Action Order_05042021_(21-207810)_text.pdf, page 3CPF 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.#

12021034CAO_Amended Corrective Action Order_05042021_(21-207810)_text.pdf, page 4CPF 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,#

12021034CAO_Amended Corrective Action Order_05042021_(21-207810)_text.pdf, page 5CPF 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.#

12021034CAO_Amended Corrective Action Order_05042021_(21-207810)_text.pdf, page 6CPF 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#

12021034CAO_Amended Corrective Action Order_05042021_(21-207810)_text.pdf, page 7CPF 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#

12021034CAO_Amended Corrective Action Order_05042021_(21-207810)_text.pdf, page 8CPF 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;#

12021034CAO_Amended Corrective Action Order_05042021_(21-207810)_text.pdf, page 9CPF 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.#

12021034CAO_Amended Corrective Action Order_05042021_(21-207810)_text.pdf, page 10CPF 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.#

12021034CAO_Amended Corrective Action Order_05042021_(21-207810)_text.pdf, page 11CPF 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.#

12021034CAO_Amended Corrective Action Order_05042021_(21-207810)_text.pdf, page 12CPF 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, page 1Official PDFMarch 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#

12021034CAO_Corrective Action Order_03192021_(21-207810)_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, ) ) ) ) ) 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#

12021034CAO_Corrective Action Order_03192021_(21-207810)_text.pdf, page 3CPF 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. 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 (JFK) airport. Line 602 travels to Long Island City, New York and then to LaGuardia airport. Another Buckeye pipeline, Line 607, also runs from the Linden, New Jersey terminal and supplies 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 three pipelines (601, 602, and 607) are all located in similar, marshy environments.  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 Line 602, in addition to Lines 601 and 607, are pipeline facilities subject to the pipeline safety laws in 49 U.S.C. chapter 601 and 49 C.F.R. part 195.#

12021034CAO_Corrective Action Order_03192021_(21-207810)_text.pdf, page 4CPF No. 1-2021-034-CAO Page 3  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. 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, 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 foregoing 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#

12021034CAO_Corrective Action Order_03192021_(21-207810)_text.pdf, page 5CPF No. 1-2021-034-CAO Page 4 measures is or would be hazardous to life, property, or the environment, and that failure to issue this Order expeditiously would result in the likelihood of serious harm. Accordingly, this Order mandating immediate corrective action is issued expeditiously without prior notice and opportunity for a hearing. The terms and conditions of this Order are effective upon receipt. Within 10 days of receipt of this 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, PHMSA will consider amending this Order. 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, Buckeye’s 12-inch Line 601, and Buckeye’s 8-inch Line 607, all located in Linden, New Jersey. 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. 2. Shutdown of the Isolated Segment. The Isolated Segment is currently out of service. The Isolated Segment must remain shut-in and may not be operated until authorized to be restarted by the Director in accordance with the terms of this Order. Operating Pressure Restriction. Buckeye must reduce and maintain a twenty percent (20%) pressure reduction in the actual operating pressure along the entire remaining length of the Affected Pipelines such that the operating pressure along the remaining length of the Affected Pipelines will not exceed eighty percent (80%) of the actual operating pressure in effect immediately prior to the failure on March 16, 2021.#

12021034CAO_Corrective Action Order_03192021_(21-207810)_text.pdf, page 63. CPF No. 1-2021-034-CAO Page 5 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. b. Within 15 days of receipt of this Order, Respondent must provide 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. Prior to resuming operation of the Isolated Segment, develop and submit a written Restart Plan to the Director for prior approval. a. b. The Director may approve the Restart Plan incrementally without approving the entire plan, but the Isolated Segment cannot resume operation until the Restart Plan is approved in its entirety. Once approved by the Director, the Restart Plan will be incorporated by reference into this Order. c. The Restart Plan must provide for adequate patrolling of the Isolated Segment during the restart process and must include incremental pressure increases during start up, with each increment to be held for at least two hours. d. The Restart Plan must include sufficient surveillance of the pipeline during each pressure increment to ensure that no leaks are present when operation of the line resumes. e. f. The Restart Plan must specify a day-light restart and include advance communications with local emergency response officials. The Restart Plan must provide for a review of the Isolated Segment for conditions similar to those of the failure including a review of construction, operating, and maintenance (O&M) and integrity management records such as ILI results, hydrostatic tests, root cause failure analysis of prior failures, aerial and ground patrols, corrosion, cathodic protection, excavations, and pipe replacements. Respondent must address any findings that require remedial measures to be#

12021034CAO_Corrective Action Order_03192021_(21-207810)_text.pdf, page 7CPF No. 1-2021-034-CAO Page 6 4. implemented prior to restart. g. The Restart Plan must also include documentation of the completion of all mandated actions, and a management of change plan to ensure that all procedural modifications are incorporated into Respondent’s O&M procedures manual. h. The Restart Plan must provide for hydrostatic pressure testing of the Isolated Segment. Return to Service. After the Director approves the Restart Plan, Respondent may return the Isolated Segment to service but the operating pressure must not exceed the pressure restrictions in accordance with Item 2 above. 5. Removal of Pressure Restriction. 6. 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. Within 45 days of receipt of this Order, 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. Document the chain-of-custody when handling and transporting the failed pipe section and other evidence from the failure site. b. c. d. Within 10 days of receipt of this Order, develop and submit the testing protocol and the proposed testing laboratory to the Director for prior approval. 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. 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.#

12021034CAO_Corrective Action Order_03192021_(21-207810)_text.pdf, page 8CPF No. 1-2021-034-CAO Page 7 7. Root Cause Failure Analysis. Within 120 days following receipt of this Order, 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 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 120 days following receipt of this Order, 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 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 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#

12021034CAO_Corrective Action Order_03192021_(21-207810)_text.pdf, page 9f. g. h. i. CPF No. 1-2021-034-CAO Page 8 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; 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 Order. 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 Order, and to incorporate modifications required by the Director. Submit any plan revisions to the Director for prior approval. i. ii. The Director may approve plan revisions incrementally. All revisions to the RWP after it has been approved and incorporated by reference into this Order will be fully described and documented in the CAO Documentation Report, see below. Implement the RWP as it is approved by the Director, including any revisions to the plan.#

12021034CAO_Corrective Action Order_03192021_(21-207810)_text.pdf, page 10CPF No. 1-2021-034-CAO Page 9 9. Instrumented Leakage Survey. Within 30 days of receipt of this Order, Respondent must perform an aerial or ground instrumented leakage survey of the Affected Pipeline. 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 Order. 10. Records Verification. As outlined in PHMSA Advisory Bulletin 2012-06, Respondent must verify the records for the Affected Pipeline to confirm the MOP. Respondent must submit documentation of this this record verification to the Director within 45 days of receipt of this Order. 11. Review of Prior Inline Inspection (ILI) Results. Within 30 days of receipt of this Order, 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 Pipeline. Respondent must submit documentation of this ILI review to the Director within 60 days of receipt of this 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 Pipeline. 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.#

12021034CAO_Corrective Action Order_03192021_(21-207810)_text.pdf, page 11CPF No. 1-2021-034-CAO Page 10 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 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 Order prior to approving the closure of this Order. The intent is for the CDR to summarize all activities and documentation associated with this Order in one document. a. b. 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 Order. c. 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 Order; v. vi. vii. Summary of the mechanical and metallurgical testing as required by the Order; Summary of the RCFA with all root causes as required by the 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 Order and whenever necessary to incorporate new information obtained during the failure investigation and remedial activities; ix. x. Lessons learned while completing this 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 Order; and xi. Appendices (if required). Other Requirements: 15. Approvals. With respect to each submission that under this Order 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.#

12021034CAO_Corrective Action Order_03192021_(21-207810)_text.pdf, page 12CPF No. 1-2021-034-CAO Page 11 16. Extensions of Time. The Director may grant an extension of time for compliance with any of the terms of this Order upon a written request timely submitted demonstrating good cause for an extension. 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 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 CAO. 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 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 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 Order are effective upon service in accordance with 49 C.F.R. § 190.5. March 19, 2021 _________________________________ ________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#