BUCKEYE PARTNERS, LP — Corrective Action Order

party submissionOfficial PDF12024055CAO_Operator Request for Hearing and Request for Informal Meeting_09232024_(24-319516).pdf#

party submissionOfficial PDF12024055CAO_Operator Withdrawal of Hearing Request_11132024_(24-319516).pdf#

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf, page 1Official PDFNovember 8, 2024 VIA ELECTRONIC MAIL TO: trusso@buckeye.com Todd Russo Chief Executive Officer Buckeye Partners, LP 4200 Westheimer Road, Suite 975 Houston, Texas 77027 CPF No. 1-2024-055-CAO Dear Mr. Russo: Enclosed please find the Amended Corrective Action Order (ACAO 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 to take certain corrective actions with respect to the September 5, 2024, leak of gasoline from its hazardous liquid pipeline facilities in Linden, New Jersey. Service of the ACAO 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: ACAO cc: Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS Mr. Robert Burrough, Director, Eastern Region, OPS Mr. Craig Brown, Vice President, Environmental & DOT Compliance Buckeye Partners, LP, cbrown@buckeye.com#

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf, page 2Mr. Robert Osika, Director, DOT Compliance, Buckeye Partners, LP, rosika@buckeye.com Mr. Mark Copeland, Manager, Pipeline Safety & DOT Compliance, Buckeye Partners, LP, mcopeland@buckeye.com Ms. Catherine Little, Esq., Counsel for Buckeye Partners, LP, Bracewell, LLP, catherine.little@bracewell.com CONFIRMATION OF RECEIPT REQUESTED#

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf, page 3U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ In the Matter of ) Buckeye Partners, LP, ) CPF No. 1-2024-055-CAO ) ) ) Respondent. ) ____________________________________) AMENDED CORRECTIVE ACTION ORDER Purpose and Background This Amended Corrective Action Order (ACAO 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 and 49 C.F.R. § 190.233, 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 September 5, 2024, release from its hazardous liquid pipeline facilities located near Linden, New Jersey (Accident). Respondent operates a hazardous liquid pipeline system that includes over 5,000 miles of pipeline across several locations in the United States, including in the Linden, New Jersey area. Buckeye’s hazardous liquid facilities in the Linden area include numerous pipelines traversing the states of New Jersey, New York, and Pennsylvania, including breakout tanks, a pump station, and two 12-inch hazardous liquid pipelines (Lines 601 and 602) running between Linden, New Jersey and Long Island, New York (approximately 2.8 miles in length). Line 602 is a hazardous liquid pipeline facility subject to the pipeline safety laws in 49 U.S.C. chapter 601 and 49 C.F.R. part 195. At approximately 6:00 P.M. Eastern Daylight Time (EDT)1, on September 5, 2024, Respondent was notified by personnel of another local pipeline operator of an odor in the area of Buckeye’s 12-inch hazardous liquid pipeline, Line 602, in Linden, New Jersey. Respondent’s subsequent investigation discovered that a leak of unleaded gasoline was occurring from Line 602, resulting in the release of approximately ten gallons of hazardous liquid. In response, Buckeye closed remote block valves, shut down Line 602, and dispatched personnel to the site. There were no reports of fires, injuries, fatalities or evacuations. Pursuant to 49 U.S.C. § 60117, PHMSA’s OPS initiated an investigation of the Accident and, on 1 All times specified in this order reflect EDT.#

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf, page 4September 13, 2024, issued a Corrective Action Order (CAO). Buckeye responded to the CAO on September 23, 2024, and reserved its right to a hearing under 49 C.F.R. § 190.233. The hearing in this matter is currently scheduled to occur on January 9, 2025. This ACAO includes minor revision to three preliminary findings, amends the corrective actions prescribed in the CAO, and incorporates an updated version of the restart plan that was attached to the CAO. The preliminary findings of the agency’s ongoing investigation are as follows: Amended Preliminary Findings • At approximately 6:00 P.M. on September 5, 2024, Respondent was notified by the personnel of another local pipeline operator of an odor in the area of Buckeye’s 12- inch hazardous liquid pipeline, Line 602, in Linden, New Jersey. Respondent’s subsequent investigation discovered that a leak of unleaded gasoline was occurring from Line 602, resulting in the release of approximately ten gallons of hazardous liquid. • 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. • Buckeye reported the Accident to the National Response Center (NRC) at 6:31 P.M. on September 5, 2024 (NRC Report No. 1410029), indicating the Accident resulted in the release an estimated ten gallons of unleaded gasoline. Buckeye’s investigation noted a sheen on standing water in proximity to adjacent Piles Creek. • The failure occurred in a high-consequence area, near a commercially navigable waterway – the Arthur Kill River – approximately one mile from Linden Station. Line 602 traverses several high consequence areas. • Prior to the failure, the operating pressure on Line 602 was 1,141 pounds per square inch gauge (psig). The maximum operating pressure (MOP) of the line is 1,222 psig. • Line 602 is a 12-inch nominal diameter, 0.250-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 runs from the Linden, New Jersey terminal to New Lots Junction in New York. Line 602 then travels north to Long Island City Terminal, New York and east to the JFK Airport and Inwood Terminals, also in New York. • Line 602, including the September 5, 2024, aboveground failure location, was the subject of a previous PHMSA CAO, CPF No. 1-2021-034-CAO associated with a March 2021 failure located below grade.2 2 See https://primis.phmsa.dot.gov/enforcement-data/case/12021034CAO.#

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf, page 5• On September 4, 2024, the day before the Accident, Respondent performed an in-line inspection (ILI) tool run on Line 602, utilizing both a geometry and magnetic flux leakage (MFL). The results of the ILI run are not yet available for review. • On September 7, 2024, the Director, Eastern Region, OPS, approved Respondent’s written restart plan (602 Repair and Restart Plan 9-6-24 V4; attached) for Line 602, with a 20 percent reduced operating pressure after the section of pipe where the release occurred was cut out and replaced. • PHMSA’s on-site investigation and observations of the pipe where the failure occurred noted apparent external metal loss due to corrosion. Determination of Necessity for Corrective Action Order and Right to Hearing On October 11, 2024, Buckeye submitted a request for amendments to the CAO for PHMSA’s consideration. The requested changes included amendments to applicable deadlines specified in Corrective Actions 1(e), 3, 7, and 11. The requested changes also addressed Corrective Action 2 to reflect that Line 602 is a hazardous liquid pipeline equipped with a computational pipeline monitoring (CPM) leak detection system. Pursuant to Buckeye’s request, PHMSA is amending Corrective Action 1(e) to reflect that the pressure review report must be submitted to the Director on a quarterly basis, via the quarterly report required under Corrective Action 11. This amendment reflects that the factors listed under Corrective Action 1(e) and pressure changes are not expected to change monthly. The pressure restriction and setpoint limitations required under Corrective Action 1 remain in effect until the restriction is removed by the Director (per Corrective Action 6). Buckeye also asserts it will continue to respond to and report safety-related conditions as is required under Part 195. Corrective Action 1 is also amended to reflect that the Respondent’s written restart plan was approved by the Director on September 7, 2024. Corrective Action 2 is amended below to reflect that Line 602 is equipped with computational pipeline monitoring (CPM) leak detection system, and also that Buckeye will provide the Director with documentation of its right of way patrol activities upon request. Corrective Action 2 specifies Buckeye will report any interruptions or malfunctions affecting Line 602’s CPM to the Director within 24 hours. Corrective Actions 3 and 7 are amended below to provide 60 days from issuance of the CAO for the submission of the review of prior inline ILI results and the mechanical and metallurgical testing and failure analysis of the failed pipe (by November 12, 2024). Corrective Action 11 is amended to reflect that the first quarterly report due under this ACAO must be submitted by December 13, 2024, or three months (one quarter) after issuance of the CAO. Finally, the corrective actions in this ACAO have been amended to reflect that the specified submission deadlines run from the original September 13, 2024, issuance date of the CAO. PHMSA acknowledges that some of the specified deadlines are now retrospective and have already been fulfilled. Section 60112 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 to the operator of the facility to take necessary corrective action, including suspended or#

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf, page 6restricted 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 are 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 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) 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 unknown cause of the September 5, 2024, release of gasoline; the March 2021 failure on Line 602 that resulted in PHMSA’s issuance of a previous CAO in CPF No. 1-2021-034-CAO; the presently unknown results from the September 4, 2024, inline inspection run conducted on Line 602; the location of the failure and release occurring in a high-consequence area and Line 602’s path through several high consequence areas; the area of the failure in a low-lying marshy area near a navigable body of water and near Linden, New Jersey; and the likelihood as based on past failures that similar conditions conducive to corrosion exist could exist on Line 602, I find that continued operation of the Affected Segment, as defined below, without corrective 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, under 49 C.F.R. § 190.233(b), 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 ACAO, 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, OPS Eastern Region, PHMSA (Director). 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.#

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf, page 7Required Corrective Actions Definitions: Affected Segment – The "Affected 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. Operating Pressure Restriction. As specified in Buckeye’s written restart plan approved by the Director on September 7, 2024, Buckeye must reduce and maintain a twenty percent (20%) pressure reduction in the actual operating pressure along the entire length of the Affected Segment, such that the operating pressure along the Affected Segment will not exceed eighty percent (80%) of the actual operating pressure in effect immediately prior to the Accident on September 5, 2024. 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. c. d. e. Within 15 days of receipt of the CAO, Respondent must provide the Director the actual operating pressures of each pump station on the Affected Segment at the time of failure and the reduced pressure restriction set-points at these same locations. 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. When determining the pressure restriction set-points, Respondent must take into account any ILI features or anomalies present in the Affected Segment to provide for continued safe operation while further corrective actions are completed. Respondent must review the pressure restriction quarterly by analyzing the operating pressure data, taking into account any ILI features or anomalies present in the Affected Segment. Respondent must immediately reduce the operating pressure further to maintain the safe operations of the Affected Segment, if warranted by the quarterly review. Respondent must submit the results of the quarterly 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 11 of this Order below. Respondent will also respond to, and report, safety-related conditions as required by § 195.55.#

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf, page 82. 3. 4. Leak Detection Activities. Buckeye must provide documentation of its right of way patrol activities to the Director upon request. Buckeye must also report within 24-hours any interruptions or malfunctions affecting Line 602’s computational pipeline monitoring (CPM) leak detection system to the Director during the effective period of this Order. Mechanical and Metallurgical Testing. Within 60 days of receipt of the CAO, 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. Within 10 days of receipt of the CAO, develop and submit the testing protocol and the proposed testing laboratory to the Director for prior approval. 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. Within 120 days of receipt of the CAO, 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 (which is without relationship to third parties used in complying with the RCFA requirement in CPF No. 1-2021-034-CAO) 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. The RCFA must also address how a potential corrosion condition, if found to be applicable to the cause of this Accident, was not identified and remediated under the past CAO, CPF No. 1-2021-034- CAO. 5. Remedial Work Plan (RWP). a. Within 30 days following submission of the RCFA, Respondent must submit to the Director for approval a remedial work plan (RWP) that addresses the conditions described in the RCFA that contributed to the Accident. b. c. 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. d. The RWP must specify the tests, inspections, assessments, evaluations, and remedial measures Respondent will use to verify the integrity of the Affected Segment. It must address all known or suspected contributing factors to the Accident. Respondent must consider the risks and consequences of another failure to develop a prioritized#

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf, page 9e. schedule for RWP-related work along the Affected Segment. The RWP must include a procedure or process to: i. Identify pipe in the Affected Segment 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 Segment 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 Segment, including pertinent information associated with the RWP created under CPF No. 1-2021-034-CAO. 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 Segment. 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 Segment. At a minimum, this process must consider all failure causes and use: 1) ILI tools with ultrasonic thickness (UT) measurement technology, or 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, such as DCVG/ACVG; 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#

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf, page 10f. g. 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 Segment, 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 Segment. 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 Segment 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. h. 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. i. Implement the RWP as it is approved by the Director, including any revisions to the plan. 6. Removal of Pressure Restriction. 7. 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 Segment to its 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 Segment 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. Review of Prior Inline Inspection (ILI) Results. Within 60 days of receipt of the CAO, Respondent must conduct a review of the September 4, 2024, ILI results of the Affected Segment. In its review, Respondent must also re-evaluate all ILI results from the past 10#

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf, page 118. 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 Segment. Respondent must submit documentation of this ILI review to the Director no later than when the RCFA is required to be submitted (120 days after issuance of the CAO) under Item 5 above 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 Segment. d. Explain the process used to review the ILI results and the results of the reevaluation. 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 Segment; 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. Lessons learned while completing this Order;#

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf, page 12x. 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: 9. 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. 10. 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. 11. 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 December 13, 2024. The Director may change the interval for the submission of these reports. 12. Documentation of 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. 1-2024-055-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.#

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf, page 13Respondent 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. November 8, 2024 _________________________________ ________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety Attachment#

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf, page 1Official PDFSeptember 13, 2024 VIA ELECTRONIC MAIL TO: trusso@buckeye.com Todd Russo Chief Executive Officer Buckeye Partners, LP 4200 Westheimer Road, Suite 975 Houston, Texas 77027 CPF No. 1-2024-055-CAO Dear Mr. Russo: 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 to take certain corrective actions with respect to the September 5, 2024, leak of gasoline from its hazardous liquid pipeline facilities 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 K. 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. Craig Brown, Vice President, Environmental & DOT Compliance Buckeye Partners, LP, cbrown@buckeye.com#

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf, page 2Mr. Robert Osika, Director, DOT Compliance, Buckeye Partners, LP, rosika@buckeye.com@buckeye.com Mr. Mark Copeland, Manager, Pipeline Safety & DOT Compliance, Buckeye Partners, LP, mcopeland@buckeye.com CONFIRMATION OF RECEIPT REQUESTED#

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf, page 3U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ In the Matter of ) Buckeye Partners, LP, ) CPF No. 1-2024-055-CAO ) ) ) Respondent. ) ____________________________________) 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 and 49 C.F.R. § 190.233, 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 September 5, 2024, release from its hazardous liquid pipeline facilities located near Linden, New Jersey (Accident). Respondent operates a hazardous liquid pipeline system that includes over 5,000 miles of pipeline across several locations in the United States, including in the Linden, New Jersey area. Buckeye’s hazardous liquid facilities in the Linden area include numerous pipelines traversing the states of New Jersey, New York, and Pennsylvania, including breakout tanks, a pump station, and two 12-inch hazardous liquid pipelines (Lines 601 and 602) running between Linden, New Jersey and Long Island, New York (approximately 2.8 miles in length). Line 602 is a hazardous liquid pipeline facility subject to the pipeline safety laws in 49 U.S.C. chapter 601 and 49 C.F.R. part 195. At approximately 6:00 P.M. Eastern Daylight Time (EDT)1, on September 5, 2024, Respondent was notified by personnel of another local pipeline operator of an odor in the area of Buckeye’s 12-inch hazardous liquid pipeline, Line 602, in Linden, New Jersey. Respondent’s subsequent investigation discovered that a leak of unleaded gasoline was occurring from Line 602, resulting in the release of approximately ten gallons of hazardous liquid. In response, Buckeye closed remote block valves, shut down Line 602, and dispatched personnel to the site. There were no reports of fires, injuries, fatalities, or evacuations. Pursuant to 49 U.S.C. § 60117, PHMSA’s OPS initiated an investigation of the Accident. The 1 All times specified in this order reflect EDT.#

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf, page 4preliminary findings of OPS’ ongoing investigation are as follows: Preliminary Findings • At approximately 6:00 P.M. on September 5, 2024, Respondent was notified by the personnel of another local pipeline operator of an odor in the area of Buckeye’s 12- inch hazardous liquid pipeline, Line 602, in Linden, New Jersey. Respondent’s subsequent investigation discovered that a leak of unleaded gasoline was occurring from Line 602, resulting in the release of approximately ten gallons of hazardous liquid. • 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. • Buckeye reported the Accident to the National Response Center (NRC) at 6:31 P.M. on September 5, 2024 (NRC Report No. 1410029), indicating the Accident resulted in the release an estimated ten gallons of unleaded gasoline. Buckeye’s investigation noted a sheen on standing water in proximity to adjacent Piles Creek. • The failure occurred in a high consequence area, near a commercially navigable waterway – the Arthur Kill River – approximately one mile from Linden Station. Line 602 traverses several high consequence areas. • Prior to the failure, the operating pressure on Line 602 was 1,141 pounds per square inch gauge (psig). The maximum operating pressure (MOP) of the line is 1,222 psig. • Line 602 is a 12-inch nominal diameter, 0.250-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 runs from the Linden, New Jersey terminal to New Lots Junction in New York. Line 602 then travels to Long Island City, New York, and then to LaGuardia Airport. • Line 602, including the September 5, 2024 failure location, was the subject of a previous PHMSA CAO, CPF No. 1-2021-034-CAO.2 • On September 4, 2024, the day before the Accident, Respondent performed an in-line inspection (ILI) tool run on Line 602, utilizing both a geometry and magnetic flux leakage (MFL). The results of the ILI run are not yet available for review. 2 See https://primis.phmsa.dot.gov/enforcement-data/case/12021034CAO.#

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf, page 5• On September 8, 2024, the Director, Eastern Region, OPS, approved Respondent’s written restart plan (attached) for Line 602, with a 20 percent reduced operating pressure after the section of pipe where the release occurred was cut out and replaced. • PHMSA’s on-site investigation and observations of the pipe where the failure occurred noted apparent external metal loss due to corrosion. Determination of Necessity for Corrective Action Order and Right to Hearing Section 60112 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 to 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 are 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 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) 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 unknown cause of the September 5, 2024, release of gasoline; the March 2021 failure on Line 602 that resulted in PHMSA’s issuance of a previous CAO, CPF No. 1-2021-034-CAO; the presently unknown results from the September 4, 2024, ILI run conducted on Line 602; the location of the failure and release occurring in a high consequence area and Line 602’s path through several high consequence areas; the area of the failure in a low-lying marshy area near a navigable body of water and near Linden, New Jersey; and the likelihood, as based on past failures, that similar conditions conducive to corrosion exist could exist on Line 602, I find that continued operation of the Affected Segment, as defined below, without corrective 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, under 49 C.F.R. § 190.233(b), 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.#

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf, page 6Within 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, OPS Eastern Region, PHMSA (Director). 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 Segment – The "Affected 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. Operating Pressure Restriction. As specified in Buckeye’s written restart plan approved by the Director on September 8, 2024, Buckeye must reduce and maintain a twenty percent (20%) pressure reduction in the actual operating pressure along the entire length of the Affected Segment, such that the operating pressure along the Affected Segment will not exceed eighty percent (80%) of the actual operating pressure in effect immediately prior to the Accident on September 5, 2024. 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. c. d. Within 15 days of receipt of this Order, Respondent must provide the Director the actual operating pressures of each pump station on the Affected Segment at the time of failure and the reduced pressure restriction set-points at these same locations. 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. When determining the pressure restriction set-points, Respondent must take into account any ILI features or anomalies present in the Affected Segment to provide for#

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf, page 72. 3. 4. 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 Segment. Respondent must immediately reduce the operating pressure further to maintain the safe operations of the Affected Segment, 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 11 of this Order below. Instrumented Leakage Survey. Within 30 days of receipt of this Order, Respondent must perform an aerial or ground instrumented leakage survey of the Affected Segment. 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. 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. 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. 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. 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 (which is without relationship to third parties used in complying with the RCFA requirement in CPF No. 1-2021-034-CAO) 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. The RCFA must also address how a potential corrosion condition, if found to be applicable to the cause of this Accident, was not identified and remediated under the past CAO, CPF No. 1-2021-034-CAO. 5. Remedial Work Plan (RWP). a. Within 30 days following submission of the RCFA, Respondent must submit to the#

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf, page 8b. c. d. e. Director for approval a remedial work plan (RWP) that addresses the conditions described in the RCFA that contributed to the Accident. 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 Segment. It must address all known or suspected contributing factors to the Accident. Respondent must consider the risks and consequences of another failure to develop a prioritized schedule for RWP-related work along the Affected Segment. The RWP must include a procedure or process to: i. Identify pipe in the Affected Segment 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 Segment 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 Segment, including pertinent information associated with the RWP created under CPF No. 1-2021-034-CAO. 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 Segment. 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 Segment. At a minimum, this process must consider all failure causes and use: 1) ILI tools with ultrasonic thickness (UT) measurement technology, or 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, such as DCVG/ACVG;#

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf, page 9f. g. 6) Stress corrosion cracking surveys; 7) 8) Selective seam corrosion surveys; and 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 Segment, 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 Segment. 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 Segment 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. h. 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. i. Implement the RWP as it is approved by the Director, including any revisions to the plan. 6. Removal of Pressure Restriction. a. b. 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 Segment to its 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. The Director may allow the temporary removal or modification of the pressure restrictions upon a written request from Respondent demonstrating that temporary#

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf, page 107. 8. 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 Segment 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. Review of Prior Inline Inspection (ILI) Results. Within 45 days of receipt of this Order, Respondent must conduct a review of the September 4, 2024, ILI results of the Affected Segment. In its review, Respondent must also 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 Segment. Respondent must submit documentation of this ILI review to the Director no later than when the RCFA is required to be submitted (120 days after issuance of the Order) under Item 5 above 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 Segment. d. Explain the process used to review the ILI results and the results of the reevaluation. 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 Segment; iv. Summary of all tests, inspections, assessments, evaluations, and analysis required by the Order; v. Summary of the mechanical and metallurgical testing as required by the Order;#

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf, page 11vi. vii. 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: 9. 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. 10. 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. 11. 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 October 31, 2024. The Director may change the interval for the submission of these reports. 12. Documentation of 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#

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf, page 12qualifies for confidential treatment under 5 U.S.C. § 552(b). In your correspondence on this matter, please refer to “CPF No. 1-2024-055-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. September 13, 2024 _________________________________ ________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

12024055CAO_PHC Hearing Scheduled_10092024_(24-319516)_text.pdf, page 1Official PDFOctober 9, 2024 VIA ELECTRONIC MAIL TO: rosika@buckeye.com and robert.burrough@dot.gov Mr. Robert Osika Director, Regulatory Compliance Buckeye Partners, LP 6161 Hamilton Blvd. Allentown, PA 18106 Mr. Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration 840 Bear Tavern Road, Suite 300 West Trenton, NJ 08628 Re: Notice of Hearing, Buckeye Partners, LP CPF No. 1-2024-055-CAO Dear Mr. Osika and Mr. Burrough: In accordance with 49 C.F.R. § 190.211, an informal hearing will be held regarding the Corrective Action Order issued by the Pipeline and Hazardous Materials Safety Administration in the above-referenced case. The hearing will take place on January 9, 2025, beginning at 8:30 a.m. Eastern Time. The hearing will be held at the PHMSA Eastern Region office, 840 Bear Tavern Road, Suite 300, West Trenton, NJ 08628. Upon arrival at the building, attendees will be required to present photo identification to security personnel. A contact phone number for the day of the hearing is (609) 989-2171. At least 10 calendar days prior to the hearing (or by December 30, 2024), both parties must submit and exchange any additional written materials they intend to present at the hearing and the name and email address of each attendee. This information should be provided electronically. Materials not submitted by this date may be excluded. If you have any questions, please do not hesitate to contact me.#

12024055CAO_PHC Hearing Scheduled_10092024_(24-319516)_text.pdf, page 2Sincerely, Larry White Presiding Official cc: Mr. Todd Russo, Chief Executive Officer, Buckeye Partners, LP, trusso@buckeye.com Ms. Catherine Little, Esq., Counsel for Buckeye Partners, LP, Bracewell, LLP, catherine.little@bracewell.com Mr. Joseph St. Peter, OPS Eastern Region Counsel, PHMSA, joseph.st.peter@dot.gov Ms. Emma Ross, OPS Eastern Region Law Clerk, PHMSA, emma.ross@dot.gov#