{"operation":"document","citation":"CPF 12025001NOPV","title":"BUCKEYE PARTNERS, LP — Notice of Probable Violation","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2025-05-30","effective_on":null,"summary":"OPEN notice of probable violation citing 195.214(a), 195.222(a), 195.222(b), 195.228(a), 195.234(e)(5).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025001nopv.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025001nopv.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12025001nopv","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12025001NOPV","body":"Notice of Probable Violation involving BUCKEYE PARTNERS, LP. PHMSA's enforcement data identifies the cited regulations as 195.214(a),  195.222(a),  195.222(b),  195.228(a),  195.234(e)(5). The case was opened on 2025-05-30 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12025001NOPV_Final Order_09262025_(23-265078).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025001NOPV/12025001NOPV_Final%20Order_09262025_(23-265078).pdf\n\n12025001NOPV_Final Order_09262025_(23-265078)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025001NOPV/12025001NOPV_Final%20Order_09262025_(23-265078)_text.pdf\n\n12025001NOPV_Operator Response to Notice_07112025_(23-265078).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025001NOPV/12025001NOPV_Operator%20Response%20to%20Notice_07112025_(23-265078).pdf\n\n12025001NOPV_PCO_05302025_(23-265078).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025001NOPV/12025001NOPV_PCO_05302025_(23-265078).pdf\n\n12025001NOPV_PCO_05302025_(23-265078)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12025001NOPV/12025001NOPV_PCO_05302025_(23-265078)_text.pdf\n\n12025001NOPV_Final Order_09262025_(23-265078)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nSeptember 26, 2025\nVIA ELECTRONIC MAIL TO: trusso@buckeye.com\nMr. Todd Russo\nChief Executive Officer\nBuckeye Partners, LP\n4200 Westheimer Road\nSuite 975\nHouston, Texas 77027\nRe: CPF No. 1-2025-001-NOPV\nDear Mr. Russo:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation and specifies actions that need to be taken to comply with the pipeline safety\nregulations. When the terms of the compliance order are completed, as determined by the\nDirector, Eastern Region, this enforcement action will be closed. Service of the Final Order by\ne-mail is effective upon the date of transmission and acknowledgement of receipt as provided\nunder 49 CFR § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosures (Final Order and NOPV)\ncc: Robert Burrough, Director, Eastern Region, Office of Pipeline Safety, PHMSA\nRobert C. Osika, Director, DOT Compliance, Buckeye Partners, LP,\nROsika@buckeye.com\nCONFIRMATION OF RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\nIn the Matter of )\nBuckeye Partners, LP, ) CPF No. 1-2025-001-NOPV\n)\n)\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nOn May 30, 2025, pursuant to 49 CFR § 190.207, the Director, Eastern Region, Office of\nPipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Buckeye Partners, LP\n(Respondent). The Notice proposed finding that Respondent had violated the pipeline safety\nregulations in 49 CFR Part 195. The Notice also proposed certain measures to correct the\nviolations. Respondent did not contest the allegations of violation or corrective measures.\nBased upon a review of all of the evidence, pursuant to § 190.213, I find Respondent violated the\npipeline safety regulations listed below, as more fully described in the enclosed Notice, which is\nincorporated by reference:\n49 CFR § 195.214(a) (Item 1) ─ Respondent failed to perform welding in\naccordance with welding procedures qualified under Section 5 of American\nPetroleum Institute Standard 1104.\n49 CFR § 195.222(a) (Item 2) ─ Respondent failed to qualify each welder in\naccordance with Section 6 of American Petroleum Institute Standard 1104 or\nSection IX of American Society of Mechanical Engineers Boiler and Pressure\nVessel Code.\n49 CFR § 195.222(b) (Item 3) ─ Respondent failed to qualify its welders.\n49 CFR § 195.228(a) (Item 4) ─ Respondent failed to visually inspect each weld\nand welding.\n49 CFR § 195.234(e)(5) (Item 5) ─ Respondent failed to nondestructively test all\ngirth welds over their entire circumference installed within populated areas.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\n\n\n\naction taken against Respondent.\nCompliance Actions\nPursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the\nactions proposed in the enclosed Notice to correct the violations. The Director may grant an\nextension of time to comply with any of the required items upon a written request timely\nsubmitted by the Respondent and demonstrating good cause for an extension. Upon completion\nof the ordered actions, Respondent may request that the Director close the case. Respondent\npreviously submitted evidence to show appropriate actions have been taken to correct the\nviolations. This evidence is currently under review by the Director. Failure to comply with this\nOrder may result in the assessment of civil penalties under 49 CFR § 190.223 or in referral to the\nAttorney General for appropriate relief in a district court of the United States.\nThe terms and conditions of this order are effective upon service in accordance with 49 CFR\n§ 190.5.\n__________________________________ _________________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n\n\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\n609.771.7800\nNOTICE OF PROBABLE VIOLATION\nand\nPROPOSED COMPLIANCE ORDER\nVIA ELECTRONIC MAIL TO: trusso@buckeye.com\nMay 30, 2025\nMr. Todd Russo\nChief Executive Officer\nBuckeye Partners, LP\n4200 Westheimer Road, Suite 975\nHouston, Texas 77027\nCPF 1-2025-001-NOPV\nDear Mr. Russo:\nFrom July 10, 2023, to January 18, 2024, a representative of the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected\nBuckeye Partners, LP’s (Buckeye) construction records, as part of the first integrated inspection of the\nTampa Pipelines L931 and L932 (Tampa Pipelines), in Allentown, Pennsylvania, and Tampa, Florida.\nAs a result of the inspection, PHMSA’s Office of Pipeline Safety, Eastern Region, alleges that you\nhave committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal\nRegulations (CFR). The items inspected and the probable violations are:\n1. § 195.214 Welding procedures.\n(a) Welding must be performed by a qualified welder or welding\noperator in accordance with welding procedures qualified under section\n5, section 12, Appendix A or Appendix B of API Std 1104 (incorporated\nby reference, see § 195.3), or Section IX of the ASME Boiler and Pressure\nVessel Code (ASME BPVC) (incorporated by reference, see § 195.3). The\nquality of the test welds used to qualify the welding procedures must be\ndetermined by destructive testing.\nBuckeye failed to perform welding in accordance with welding procedures qualified under section 5\nof American Petroleum Institute (API) Standard 1104, 20th Edition, Section 5 (API Standard 1104) in\naccordance with section 195.214(a). Specifically, Buckeye failed to perform post-weld heat treatment\n\n\n\nCPF 1-2025-001-NOPV\n(PWHT) on all welds as required by its qualified welding procedure for the 1.6-mile Tampa Pipeline\n(Tampa Pipeline L931).\nDuring the inspection, PHMSA reviewed Daily Weld Logs (Weld Logs) and Radiographic Grader\nSheets (NDE Reader Sheets) provided by Buckeye for its Tampa Pipelines L931 and L932. PHMSA\nalso reviewed Buckeye’s Weld Procedure Specification (WPS) P16 PWHT, which, according to\nBuckeye, was the qualified welding procedure used to produce all the girth welds of the Tampa\nPipelines L931 and L932. WPS P16 PWHT is a fixed-position butt weld procedure qualified under\nsection 5 of API Standard 1104 and requires a PHWT consisting of heating at 1,200°F ± 20 °F for a\none hour minimum, and heating and cooling above 700°F controlled at 400°F per hour. However,\nneither the Weld Logs nor the NDE Reader Sheets specifically recorded WPS P16 PWHT as the\nwelding procedure that was followed to produce the welds. Also, while the NDE Reader Sheets\nrecorded post-weld heat treatment applied to welds of Pipeline L932, they did not record post-weld\nheat treatment for any of the three-hundred seven (307) welds produced to construct Pipeline L931.\nBuckeye did not provide any other evidence of post-weld heat treatment applied to welds of Pipeline\nL932. Furthermore, Buckeye stated that all girth welds of Pipelines L931 and L932 were produced\nusing WPS P16 PWHT, but that it only performed post-weld heat treatment on Pipeline L932 welds\n(see Exhibit D-03). Post-weld heat treatment was part of the welding procedure P16 PWHT, which\nwas qualified pursuant to the requirements of § 195.214(a). However, Buckeye acknowledged that it\nfailed to perform the required PWHT on all three-hundred seven (307) welds produced to construct\nTampa Pipeline L931.\nTherefore, Buckeye failed to perform welding in accordance with welding procedures qualified under\nsection 5 of API Standard 1104 in accordance with section 195.214(a).\n2. § 195.222 Welders and welding operators: Qualification of welders and welding\noperators.\n(a) Each welder or welding operator must be qualified in accordance\nwith section 6, section 12, Appendix A or Appendix B of API Std 1104\n(incorporated by reference, see § 195.3), or section IX of the ASME Boiler\nand Pressure Vessel Code (ASME BPVC), (incorporated by reference, see\n§ 195.3) except that a welder or welding operator qualified under an\nearlier edition than listed in § 195.3, may weld but may not requalify under\nthat earlier edition.\nBuckeye failed to qualify each welder in accordance with section 195.222(a). Specifically, Buckeye\nfailed to qualify eight (8) welders in accordance with API Standard 1104, or Section IX of ASME\nInternational (ASME) Boiler and Pressure Vessel Code (BPVC), as required by section 195.222(a)\n(and incorporated by reference in sections 195.3(b)(20) and 195.3(c)(7), respectively).\nDuring the inspection, PHMSA reviewed the qualification records for nine (9) welders who completed\nproduction welds during construction of Tampa Pipelines L931 and L932 from 2018 to 2020. Two (2)\nof the welders, with welder ID symbols EA and ND, had welding certificates issued by Buckeye dated\n12/19/19, and signed by an American Welding Society (AWS) certified welding inspector (CWI). The\nwelding certificates stated, in part, that the welders had passed Buckeye’s welder qualification Test A.\nAccording to Section A-02_3.1 of Buckeye’s Welding Manual 04-02.WELDM.0001, Revision 4,\n7/24/23 (Welding Manual), Test A is a single qualification test to conduct production butt welding in\naccordance with API Standard 1104 and, to weld in all positions, each welder should make a butt weld\n12025001NOPV_Final Order_09262025_(23-265078).docx Page 2 of 8\n\n\n\nCPF 1-2025-001-NOPV\nusing Buckeye’s Form A - Welder Single Qualification (WE A-02 Form A), updated 5/21/18 (see\nExhibit A-01). Section A-02_4 of Buckeye’s Welding Manual states, in part, that all information\npertaining to the welder qualification test is to be recorded on the Company’s “Welders Qualification\nReport” Form A - Welder Single Qualification (Test A). However, Buckeye was unable to furnish\nForm A for welder ID symbols EA or ND, or any other record as evidence adequately detailing the\nresults of each welder’s qualifying test, in accordance with Section 6 of API Standard 1104.\nFor three (3) other welders, with ID symbols PH/1297, ALN/0089, and LS/2938, Buckeye provided\nwelder qualification test reports in accordance with Section IX of the ASME BPVC dated 7/23/2019\nand signed by a CWI. However, according to the Weld Logs and a list of welds (see Exhibits B-03, B-\n04, and B-05) provided by Buckeye, these three welders (PH/1297, ALN/0089, and LS/2938)\ncompleted their first production welds on 5/23/2019, 4/6/2019, and 5/21/2019, respectively, or before\nobtaining the qualifications on 7/23/2019. Buckeye did not present any other qualification records for\nthe welders by the time they started to produce welds. In addition, these three welders produced welds\nusing Buckeye’s Weld Procedure Specification P16 PWHT, Rev. 1, dated 10/01/2018, which was\nqualified and written in accordance with the requirements of API Standard 1104 and not section IX of\nthe ASME BPVC. Thus, these three welders’ qualifications were not consistent with Buckeye’s\nwelding procedure P16 PWHT in that they did not obtain their qualifications by following welding\nprocedures qualified according to API Standard 1104. Further, the qualification records provided by\nBuckeye for the welders indicated that procedure QW-461-4(d) was used for the qualification test,\nwhich is not a Buckeye qualified welding procedure (rather a test position as described in Section IX\nof the ASME BPVC). Therefore, the qualification records provided by Buckeye failed to demonstrate\nthat these welders were qualified prior to the production of welds and that a qualified welding\nprocedure was used for their qualification tests.\nBuckeye also provided welder qualification test reports in accordance with Section IX of the ASME\nBPVC for three (3) welders with ID symbols AN/5905, JF/1260, and WZ/301. The qualification\nreports for welders AN/5905 and JF/1260 were dated 3/16/2018, while welder WZ/301’s qualification\nreport was dated 10/21/2019. All three (3) welder qualification reports were signed by a CWI. The\nqualifications records for the welders AN/5905 and JF/1260 indicated that the procedure QW-461-4(d)\nwas used for the qualification test, which is not a Buckeye qualified welding procedure, but instead is\na test position as described in Section IX of the ASME BPVC. The qualification report provided for\nthe welder WZ/301 indicated that the procedure PW02SM1-1 was used for the qualification test.\nHowever, PW02SM1-1 is not a Buckeye qualified welding procedure or a procedure for which\nBuckeye had qualification records. Therefore, Buckeye failed to demonstrate that a qualified welding\nprocedure was used for the qualification test of the welders AN/5905, JF/1260, and WZ/301.\nIn summary, Buckeye failed to provide qualification records or any other evidence of adequate\nqualification, pursuant to the requirements of Section 6 of API Standard 1104 or Section IX of the\nASME BPVC, for eight (8) welders who completed production welds during construction of the Tampa\nPipelines L931 and L932.\nTherefore, Buckeye failed to qualify each welder in accordance with section 195.222(a).\n3. § 195.222 Welders and welding operators: Qualification of welders and welding\noperators.\n(a) …\n12025001NOPV_Final Order_09262025_(23-265078).docx Page 3 of 8\n\n\n\nCPF 1-2025-001-NOPV\n(b) No welder or welding operator may weld with a welding process\nunless, within the preceding 6 calendar months, the welder or welding\noperator has –\n(1) Engaged in welding with that process; and\n(2) Had one weld tested and found acceptable under section 9 or\nAppendix A of API Std 1104 (incorporated by reference, see § 195.3).\nBuckeye failed to qualify its welders in accordance with section 195.222(b). Specifically, for a welder\nwho completed production welds with a welding process, Buckeye failed to provide any records to\nensure that, within the preceding 6 calendar months, the welder had engaged in welding with the same\nprocess and had a weld tested and found acceptable according to the requirements of\nsection 195.222(b).\nDuring the inspection, Buckeye provided a multiple qualification test report dated 2/5/19 and signed\nby an AWS CWI for a welder with ID symbol SW/9744. This welder’s first production weld, as shown\non the Weld Logs, was completed on 2/15/2020. However, Buckeye failed to provide records\nindicating that welder SW/9744 engaged with that welding process or had a weld tested and found\nacceptable under Section 9 or Appendix A of API Standard 1104 within the six (6) calendar months\npreceding the weld completion date of 2/15/2020.\nTherefore, Buckeye failed to qualify its welders in accordance with section 195.222(b).\n4. § 195.228 Welds and welding inspection: Standards of acceptability.\n(a) Each weld and welding must be inspected to insure compliance with\nthe requirements of this subpart. Visual inspection must be supplemented\nby nondestructive testing.\nBuckeye failed to inspect each weld and welding in accordance with section 195.228(a). Specifically,\nBuckeye failed to visually inspect forty-one (41) of the production welds completed for the\nconstruction of its Tampa Pipelines L931 and L932.\nDuring the inspection, PHMSA reviewed the Weld Logs, Pipeline Weld Maps (Weld Maps), and a list\nof welds (see Exhibit B-05) provided by Buckeye for its Tampa Pipelines L931 and L932. According\nto Buckeye, the Weld Logs recorded the visual inspection of the production welds completed during\nthe construction of the Tampa Pipelines L931 and L932.1 However, Buckeye failed to provide both\nthe Weld Logs and any visual inspection records for forty-one (41) production welds for the Pipelines\nL931 and L932.2\nTherefore, Buckeye failed to inspect each weld and welding in accordance with section 195.228(a).\n5. § 195.234 Welds: Nondestructive testing.\n1 The Weld Logs were not signed by an AWS CWI, or a person for whom Buckeye had provided any records of\nbeing trained and qualified to perform inspection either, pursuant to the requirements of section 195.204.\n2 Weld numbers: 1534, 1535, 1536, 1537, 1538, 1539, 1540, 1541, 1542, 1543, 1543, 1544, 1545, 1546, 1547, 1548,\n1549, 1550, 1551, 1553, 1554, 1555, 1556, 1557, 1558, 1559, 1560, 1562, 1563, 1564, 1565, 1566, 1567, 1568,\n1570, 1571, 1573, 1574, 1575, 1576, and 1577.\n12025001NOPV_Final Order_09262025_(23-265078).docx Page 3 of 8\n\n\n\nCPF 1-2025-001-NOPV\n(a) …\n(e) All girth welds installed each day in the following locations must\nbe nondestructively tested over their entire circumference, except that\nwhen nondestructive testing is impracticable for a girth weld, it need not\nbe tested if the number of girth welds for which testing is impracticable\ndoes not exceed 10 percent of the girth welds installed that day:\n(1) …\n(5) Within populated areas, including, but not limited to, residential\nsubdivisions, shopping centers, schools, designated commercial areas,\nindustrial facilities, public institutions, and places of public assembly.\nBuckeye failed to nondestructively test all girth welds over their entire circumference installed within\npopulated areas in accordance with section 195.234(e)(5). Specifically, Buckeye failed to\nnondestructively test four (4) welds3 over their entire circumference all of the production girth welds\ncompleted within populated areas during the construction of its Tampa Pipeline L931.\nDuring the inspection, PHMSA reviewed the Weld Logs, the Weld Maps, and the nondestructive\nexamination (NDE) Reader Sheets provided by Buckeye for its Tampa Pipeline L931. The NDE\nReader Sheets recorded the nondestructive test of production girth welds over their entire\ncircumference for the Tampa Pipeline L931, which was constructed within a high consequence area.\nHowever, there were four (4) welds (weld numbers 1513, 1514, 1515, and 1562) on the Weld Logs\nand Weld Maps for which Buckeye failed to provide any non-destructive test records or an engineering\njustification as to why nondestructive testing was impracticable for those girth welds.\nTherefore, Buckeye failed to nondestructively test all girth welds over their entire circumference\ninstalled within populated areas in accordance with section 195.234(e)(5).\nProposed Civil Penalty\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$272,926 per violation per day the violation persists, up to a maximum of $2,729,245 for a\nrelated series of violations. For violation occurring on or after December 28, 2023 and before\nDecember 30, 2024, the maximum penalty may not exceed $266,015 per violation per day the\nviolation persists, up to a maximum of $2,660,135 for a related series of violations. For violation\noccurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may\nnot exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627\nfor a related series of violations. For violation occurring on or after March 21, 2022 and before\nJanuary 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the\nviolation persists, up to a maximum of $2,391,412 for a related series of violations. For violation\noccurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not\nexceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for\na related series of violations. For violation occurring on or after January 11, 2021 and before\nMay 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation\npersists, up to a maximum of $2,225,034 for a related series of violations. For violation\noccurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not\n3 Weld numbers: 1513, 1514, 1515, and 1562.\n12025001NOPV_Final Order_09262025_(23-265078).docx Page 5 of 8\n\n\n\nCPF 1-2025-001-NOPV\nexceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for\na related series of violations.\nWe have reviewed the circumstances and supporting documentation involved in this case, and have\ndecided not to propose a civil penalty assessment at this time.\nProposed Compliance Order\nWith respect to items 1, 2, 3, 4, and 5, pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous\nMaterials Safety Administration proposes to issue a Compliance Order to Buckeye Partners, LP.\nPlease refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in\nEnforcement Proceedings. Please refer to this document and note the response options. All material\nyou submit in response to this enforcement action may be made publicly available. If you believe that\nany portion of your responsive material qualifies for confidential treatment under 5 U.S.C. § 552(b),\nalong with the complete original document you must provide a second copy of the document with the\nportions you believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. § 552(b).\nFollowing your receipt of this Notice, you have 30 days to respond as described in the enclosed\nResponse Options. If you do not respond within 30 days of receipt of this Notice, this constitutes a\nwaiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator\nfor Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue a\nFinal Order. If you are responding to this Notice, we propose that you submit your correspondence to\nmy office within 30 days from receipt of this Notice. The Region Director may extend the period for\nresponding upon a written request timely submitted demonstrating good cause for an extension.\nIn your correspondence on this matter, please refer to CPF 1-2025-001-NOPV and, for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Enforcement Proceedings\n12025001NOPV_Final Order_09262025_(23-265078).docx Page 6 of 8\n\n\n\nCPF 1-2025-001-NOPV\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Buckeye Partners, LP (Buckeye) a Compliance Order\nincorporating the following remedial requirements to ensure the compliance of Buckeye with the\npipeline safety regulations:\nA. In regard to Items 1-5 of the Notice pertaining to Buckeye’s failure to follow a qualified\nwelding procedure, failure to use qualified welders in certain instances, and failure to\ninspect welds as required, within 90 days of receipt of the Final Order, Buckeye must\ntake the following corrective actions on Tampa Pipelines L931 and L932:\n1. Remove and destructively test a minimum of 5% of the production welds\ncompleted during the construction of Tampa Pipelines L931 and L932.\nSelection of the welds to be removed, destructively tested and replaced, must\ninclude any weld without records of visual inspection or nondestructive testing\nand incorporate at least one (1) weld completed by each welder not qualified\npursuant to the requirements of section 195.222(a) or section 195.222(b).\n2. Re-examine a minimum of 5% of the radiographs obtained as part of the\nnondestructive evaluation of the production welds completed during the\nconstruction of Tampa Pipelines L931 and L932 per Buckeye procedures. Any\nweld rejected as a result of the re-examination shall be removed and replaced,\nunless two (2) or more independent NDE subject matter experts (SME),\nqualified as Level III under ASNT SNT-TC-1A certification, determine that\nthe weld should not be rejected.\n3. If removal and replacement of any weld is not feasible within the 90-day period\nof the Final Order, Buckeye must notify the Director, Eastern Region, Office\nof Pipeline Safety (Director) and explain how it will address the weld(s) in\nquestion.\n4. Remedial actions required by this Compliance Order shall be performed in\naccordance with the requirements of all applicable subparts of 49 CFR Part\n195.\n5. Notify the Director at least 15 days in advance of starting any of the testing and\nconstruction activities required by this Compliance Order.\n6. Provide copies of any records pertaining to the corrective actions described in\nthis Compliance Order, as required by the Director, including, but not limited\nto the updated weld maps for the Tampa Pipelines L931 and 932, and an\nupdated list of the welds produced for both pipelines, indicating for each weld:\na) the welders used to complete it; b) the welding procedure followed; and, c)\nthe detailed record of its visual inspection and nondestructive\ntesting/evaluation (e.g., name, number, page, date, etc.).\n12025001NOPV_Final Order_09262025_(23-265078).docx Page 7 of 8\n\n\n\nCPF 1-2025-001-NOPV\n7. Submit a final report to the Director, describing in detail the results of all\ncorrective actions taken to ensure Tampa Pipelines L931 and L932 comply\nwith the requirements of Part 195.\nB. It is requested (not mandated) that Buckeye Partners, LP maintain documentation of\nthe safety improvement costs associated with fulfilling this Compliance Order and\nsubmit the total to the Director. It is requested that these costs be reported in two\ncategories: 1) total cost associated with preparation/revision of plans, procedures,\nstudies and analyses, and 2) total cost associated with replacements, additions and other\nchanges to pipeline infrastructure.\n12025001NOPV_Final Order_09262025_(23-265078).docx Page 8 of 8","truncated":false,"body_characters":27338}