BUCKEYE PARTNERS, LP — Notice of Amendment

party submissionOfficial PDF12026051NOA_Operator Response to Notice_05292026_(25-332203).pdf#

12026051NOA_Closure Letter_06262026_(25-332203)_text.pdf, page 1Official PDFU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 840 Bear Tavern Road, Suite 300 West Trenton, New Jersey 08628 609.771.7800 VIA EMAIL TO: trusso@buckeye.com June 26, 2026 Todd Russo President and Chief Executive Officer Buckeye Partners, LP 4200 Westheimer Road #975 Houston, Texas 77027 RE: CPF 1-2026-051-NOA Dear Mr. Russo: From March 17 through November 13, 2025, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), Eastern Region, pursuant to Chapter 601 of Title 49 United States Code (U.S.C.), conducted an integrated inspection of Buckeye Partners, LP’s (Buckeye) plans and procedures for maintenance and normal operations in Allentown, Pennsylvania. As a result of the inspection, PHMSA issued a Notice of Amendment on May 4, 2026, which proposed amendments to Buckeye’s procedures. Buckeye submitted its amended procedures on May 29, 2026. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration cc: Mark Copeland, Manager, Pipeline Safety & DOT Compliance, mcopeland@buckeye.com Robert Osika, Director, DOT Compliance, rosika@buckeye.com@buckeye.com#

12026051NOA_Notice of Amendment_05042026_(25-332203)_text.pdf, page 1Official PDFU.S. Department of Transportati on Pipeline and Hazardous Materials Safety Administration 840 Bear Tavern Road, Suite 300 West Trenton, New Jersey 08628 609.771.7800 NOTICE OF AMENDMENT VIA EMAIL TO: trusso@buckeye.com May 4, 2026 Todd Russo President and Chief Executive Officer Buckeye Partners, LP 4200 Westheimer Road #975 Houston, Texas 77027 CPF 1-2026-051-NOA Dear Mr. Russo: From March 17 through November 13, 2025, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), Eastern Region, pursuant to Chapter 601 of Title 49 United States Code (U.S.C.), conducted an integrated inspection of Buckeye Partners, LP’s (Buckeye) plans and procedures for maintenance and normal operations in Allentown, Pennsylvania. As a result of the inspection, Eastern Region has identified an inadequacy found within Buckeye’s plans or procedures. The alleged inadequacy and proposed revision is described below: 1. § 195.440 Public awareness. (a) Each pipeline operator must develop and implement a written continuing public education program that follows the guidance provided in the American Petroleum Institute's (API) Recommended Practice (RP) 1162 (incorporated by reference, see § 195.3). (b) … (g) The program must be conducted in English and in other languages commonly understood by a significant number and#

12026051NOA_Notice of Amendment_05042026_(25-332203)_text.pdf, page 2CPF 1-2026-051-NOA concentration of the non-English speaking population in the operator’s area. Buckeye’s written public awareness procedural manual was inadequate to ensure safe operation of a pipeline facility. Specifically, Buckeye’s Public Awareness Manual, Section F - Message Type and Content, Revision 11 (04/18/25) (Public Awareness Manual), failed to provide sufficient details regarding its processes to ensure compliance with the requirements of section 195.440(g). The table of contents of the Public Awareness Manual cited section 4 as the section covering the procedure for addressing message type and content. However, section 4 was identified as not applicable within the document. Section 1.4.2 in the Public Awareness Manual, regarding message content for each audience group, only identified Spanish as commonly used by a significant concentration of the non-English speaking population, and noted that Buckeye has developed certain materials in Spanish in addition to English. However, the manual failed to provide details regarding how to address areas where languages other than Spanish are commonly understood by a significant number and concentration of the non-English speaking population along the pipeline. In addition, the Public Awareness Manual failed to include a procedure to determine the number and concentration of the non-English speaking population in the operator’s area. The information in Exhibit A in the manual lacked detail as to which languages, other than English or Spanish, are most spoken, particularly for certain counties including Boone, IN, where a significant portion of the non-English speaking population speaks a language that is different than Spanish. Therefore, Buckeye’s written public awareness procedural manual was inadequate to ensure safe operation of a pipeline facility. Eastern Region proposes that Buckeye revise its procedures to address the above deficiency. Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement Proceedings. Please refer to this document and note the response options. 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under § 190.211. If you do not respond within 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice Page 2 of 3#

12026051NOA_Notice of Amendment_05042026_(25-332203)_text.pdf, page 3CPF 1-2026-051-NOA without further notice to you and to issue an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Buckeye maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 1-2026-051-NOA and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Robert Burrough Director, Eastern Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings cc: Mark Copeland, Manager, Pipeline Safety & DOT Compliance, mcopeland@buckeye.com Robert Osika, Director, DOT Compliance, rosika@buckeye.com@buckeye.com Page 3 of 3#