# BUCKEYE PARTNERS, LP — Corrective Action Order

- **operation:** document
- **citation:** CPF 12024055CAO
- **title:** BUCKEYE PARTNERS, LP — Corrective Action Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** 2024-09-13
- **effective on:** Not available
- **summary:** OPEN corrective action order.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-12024055cao.md
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/12024055CAO
**body:**

Corrective Action Order involving BUCKEYE PARTNERS, LP. The dataset does not identify a cited regulation for this case. The case was opened on 2024-09-13 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024055CAO/12024055CAO_Corrective%20Action%20Order%20(Amended)_11082024_(24-319516).pdf

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024055CAO/12024055CAO_Corrective%20Action%20Order%20(Amended)_11082024_(24-319516)_text.pdf

12024055CAO_Corrective Action Order_09132024_(24-319516).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024055CAO/12024055CAO_Corrective%20Action%20Order_09132024_(24-319516).pdf

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024055CAO/12024055CAO_Corrective%20Action%20Order_09132024_(24-319516)_text.pdf

12024055CAO_Operator Request for Hearing and Request for Informal Meeting_09232024_(24-319516).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024055CAO/12024055CAO_Operator%20Request%20for%20Hearing%20and%20Request%20for%20Informal%20Meeting_09232024_(24-319516).pdf

12024055CAO_Operator Withdrawal of Hearing Request_11132024_(24-319516).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024055CAO/12024055CAO_Operator%20Withdrawal%20of%20Hearing%20Request_11132024_(24-319516).pdf

12024055CAO_PHC Hearing Scheduled_10092024_(24-319516).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024055CAO/12024055CAO_PHC%20Hearing%20Scheduled_10092024_(24-319516).pdf

12024055CAO_PHC Hearing Scheduled_10092024_(24-319516)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12024055CAO/12024055CAO_PHC%20Hearing%20Scheduled_10092024_(24-319516)_text.pdf

12024055CAO_Corrective Action Order (Amended)_11082024_(24-319516)_text.pdf

November 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



Mr. 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



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Buckeye Partners, LP, ) 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.



September 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.



• 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



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 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.



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 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.



2. 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



e. 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



f. 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



8. 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;



x. 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.



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.
November 8, 2024
_________________________________ ________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety
Attachment

12024055CAO_Corrective Action Order_09132024_(24-319516)_text.pdf

September 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



Mr. 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



U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, D.C. 20590
____________________________________
In the Matter of )
Buckeye Partners, LP, ) 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.



preliminary 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.



• 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 appropri
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