BP OIL PIPELINE CO — Corrective Action Order

320065033h_corrective action order_03292006_text.pdf, page 1Official PDFU 5 Department of Transportation Pipeline and HozordoUs Materials Sofettr Administration 400 Seventh Street, S W Weehrngion, D C 20590 IriAl 29 Hyped„ Mr Jim Lamanna President BP Pipehnes (North America), Inc 28100 Torch Parkway Warrenville, IL 60555 Re CPF No 3-2006-5033H Dear Mr Lamanna Enclosed is a Corrective Action Order issued by the Associate Administrator for Pipehne Safety in the above-referenced case It requires you to take certain corrective actions with respect to your Toledo/West Toledo hazardous liquid pipehne, including successfully performing hydrostatic testing, before resuming operations Service is being made by certified mail and facsimile Your receipt of this Corrective Action Order constitutes service of that document under 49 C F R $ 190 5 The terms and conditions of this Corrective Action Order are effective upon receipt 3 Zpg, Sincerely, James Reynolds Pipehne Comphance Registry Enclosure cc Ivan Huntoon Director, Central Region, PHMSA#

320065033h_corrective action order_03292006_text.pdf, page 2DEPARTMENT OF TRAiVSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION WASHINGTON, DC 20590 In the Matter of ) BP Pipelines (North America), Inc. ) ) , ) ) Respondent ) CPF No 3-2006-5033H CORRECTIVE ACTION ORDER Pur ose and Bac round This Corrective Action Order is being issued, under authonty of 49 U S C ) 60112, to require BP Pipehnes (North America), Inc (Respondent) to take the necessary corrective action to protect the public, property, and the environment from potential hazards associated with a failure involving Respondent's Toledo/West Toledo hazardous hquid pipeline On March 23, 2006, Respondent discovered a leak on its 6-inch Toledo/West Toledo pipeline in Toledo, Ohio Pursuant to 49 U S C ll 60117, the Pipehne and Hazardous Matenals Safety Admiiustration (PHMSA) imtiated an investigation of the accident Prehminarv Findin s ~ On March 23, 2006, at approximately 3 00 AM CST, Respondent's personnel at its Tulsa, Oklahoma control center detected a reduction in pressure and flow on the Toledo/West Toledo pipehne At 6 11 AM CST, Respondent reported the pipehne failure to the National Response Center (NRC) (Incident Report No 791693) ~ The failure resulted in a release currently estimated at 200 barrels of unleaded gasohne from the pipeline Respondent determined the location of the failure site to be at or near Mile Post 6 7 near the intersection of Laskey and Tractor Roads on the west side of the city of Toledo, Ohio Some of the gasoline migrated via drain tile into the Shantee Creek which flows to Lake Erie Potential impacts to ground-water and the environment are not yet known No fires, in)uncs, or fatalities were reported in connection with the accident ~ Following the failure, Respondent shut down the pumps and closed the remote valve at the Toledo Refinery and ceased operating the pipehne Respondent's personnel further isolated the failed pipe section by manually closing the mam-hne valves at Mile Posts#

320065033h_corrective action order_03292006_text.pdf, page 34 66 7 08, and 8 33 Respondent also activated its spill response plan and set up containment booms along Shantee Creek ~ The cause of the failure has not yet been determined Respondent s personnel conducted a preliminary visual examination at the failure site and identified a narrow, straight, longitudinal split approximately 22-inches in length at the three o clock position on the pipe Respondent has removed the pipe Joint containing the failure ortgm for transport to a metallurgist for in-depth analysis ~ The Toledo/West Toledo pipeline is approximately 14 3 miles long and transports refined petroleum products from the Toledo Refinery to the West Toledo Terminal in Lucas County, Ohio The pipeline runs through populated areas and is in close proximity to roads and railroads The enure length of the pipeline is located in a lugh-consequence area as defined in 49 C F R lJ 195 450 Respondent's records indicate that the pipeline was installed in 1951 and is constructed of 6 625-inch diameter, 0 250-inch wall thickness, grade X-42 seamless pipe It has a coal- tar coating and is cathodically protected by impressed current It is not yet known whether the entire pipeline is seamless, or if portions of the line have welded seams, but the type of failure is charactenstic of pipe with a longitudinal seam PHMSA has issued advisory bulletins concerning the susceptibihty of pre-1970 electric-resistance welded (ERW) pipe to seam failures ~ The maximum operating pressure (MOP) of the pipehne is 700 pounds per square-mch gauge (psig) The actual operating pressure at the failure site at the time of the failure is estimated to have been 350 psig ~ The pipeline was internally mspected m 1996 and 2002 using both metal loss and geometry tools The 2002 inspection resulted in four immediate repairs which were completed by January 2003 and mvolved pipe sleeving and/or coating None of these repairs were performed at the failure site A corrosion anomaly of 26'/0 was identified in proximity to the failure site but was determined by Respondent to be witlun acceptable hmits for conunued safe operation ~ Dunng the investigation of this release. another leak was identified at an above-ground crossing located at Bennett Road on March 24, 2006 This leak appeared to be minor seepage through the pipe wall associated with external corrosion under the coating and was also reported to the NRC Determination of Necessitv for Correchve Action Order and Ri ht to Hearin Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action Order, after reasonable notice and the opportunity for a heanng when PHMSA determines that operation of a pipehne facihty is or would be hazardous The basis for determming that a pipehne facihty is hazardous, requiring corrective action, is set forth both in the above-referenced statute and 49 C F R IJ 190 233, a copy of v:hich is enclosed#

320065033h_corrective action order_03292006_text.pdf, page 4Section 60112 of Title 49, United States Code, and the regulations promulgated thereunder, provide for the issuance of a Corrective Action Order without prior opportunity for notice and heanng upon a finding that failure to issue the Order expeditiously will likely result in serious harm to life, property, or the environment In such cases, an opportunity for a hearing will be provided as soon as practicable after the issuance of the Order After evaluating the foregoing prehminary findings of fact, and consideung the age of the pipe, the hazardous nature of the product the pipehne transports, the spill volume, the proximity of the pipehne to populated areas, the proximity of the pipelme to waterways and environmentally sensitive areas, and the ongoing investigation to determine the cause of the failure, I find that the continued operation of Respondent's Toledo/West Toledo hazardous hquid pipeline without corrective measures would be hazardous to h fe, property, or the environment I further find that failure to expeditiously issue this Order requiring immediate corrective action will hkely result in serious harm to life, property, or the environment Accordingly, this Corrective Action Order mandating immediate corrective action is issued without prior notice and opportumty for heanng The terms and conditions of this Order are effective upon receipt Witlun 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 Pipehne Safety in writing, dehvered personally, by mail or by facsimile at (202) 366-4566 The hearing will be held in Kansas City, Missouri or Washington, D C on a date that is mutually convenient to PHMSA and the Respondent After receiving and analyzing additional data in the course of tlus investigation, PHMSA may identify other corrective action measures that need to be taken In that event, Respondent will be notified of any additional measures required and amendment of this Order will be considered To the extent consistent with safety considerations, Respondent will be afforded notice and an opportunity for a hearing prior to the imposition of additional corrective measures Re uired Corrective Action Pursuant to 49 U S C ) 60112, I hereby order BP Pipelines (North America), Inc to immediately take the following corrective actions with respect to its Toledo/West Toledo hazardous liquid pipeline I Prior to resuming operation of the pipehne (A) Develop and submit a written plan for prior approval of the Director, Central Region, PHMSA, to conduct a short-duration hydrostatic test to a mmimum nressure of 100% of SMYS or I 39 X MOP, followed by a 49 C F R Subpart E hydrostatic test Provide the Regional Director with the date and time of the testing which PHMSA may elect to witness Conduct the hydrostatic testing as appropnate to the#

320065033h_corrective action order_03292006_text.pdf, page 5condition(s) causing the March 23, 2006 failure, mcluding metallurgical analysis of any failures that occur dunng the testing, and (B) Obtain wntten approval prior to resuming operation from the Director, Central Region, PHMSA The Regional Director's determination will be based on whether all corrective actions required by this Order necessary to ensure the safe and environmentally sound operation of the pipehne have been completed 2 Conduct metallurgical testing of the failed pipe section as follows (A) When handhng and transportmg the failed pipe section and any other evidence from the failure site, document the chain-of-custody, (B) Obtain prior approval of the metallurgical testing laboratory to be used, as well as the testing protocol from the Director, Central Region, PHMSA, (C) Pnor to commencing the metallurgical teshng, provide the Director, Central Region, PHMSA with the scheduled date, time, and location of the testing to allow a PHMSA representative to witness it, and (D) Ensure that the laboratory distributes all resultmg metallurgical reports, whether draft or final, to PHMSA at the same time as they are made available to Respondent 3 Re-evaluate the data from the metal loss internal inspection tool and the geometry tool runs performed in 1996 and 2002, including mformation obtained from the resulting excavations/repairs, for the purpose of determimng whether any anomahes that could have contributed to the failures at Mile Post 6 7 and Bennett Street crossing were present and whether any anomalies with similar characteristics are present along the remamder of the pipeline Extract and record dimensional data of all such anomahes, including data on distance from upstream and downstream girth weld, o' clock position, minimum and maximum remainmg wall thickness, anomaly growth between internal inspections, and any remedial actions taken for each anomaly Make these internal inspection results available to PHMSA or its representative 4 Provide PHMSA with the technical)ustiftcations documenting the basis for the integrity management program re-assessment interval established for the pipeline pursuant to 49 C F R ) 195 452(1)(3) 5 Within 30 days of receipt of this Order, develop and submit a written plan with correctn e measures for prior approval by the Director, Central Region, PHMSA The plan must fully address all known or suspected factors that caused or contributed to the March 23, 2006 failure and the corrosion leak identified on March 24, 2006 and must include (A) The identification of the type of pipe, whether seamless or seamed, by mile post along the entire length of the pipeline along v ith the integration of the information#

320065033h_corrective action order_03292006_text.pdf, page 6developed from the actions required by Items 1-3 with any relevant information from records of previous failure mvestigations, leak history, repair activity, corrosion control/cathodic protection activity, in-hne inspections, hydrostatic testing, changes in pressure cychng, and other relevant operating records for the purpose of performing a comprehensive analysis of the available information associated with the factors that caused or contnbuted to the failure, (B) The performance of appropnate field teshng inspections, and evaluations, including runnmg a high-resolution internal inspection tool if necessary, to determme whether and to what extent the condition(s) associated with the failure including cracks, metal loss due to internal, external, or atmosphenc corrosion, or any other tntegrtty threatemng conditions, are present along the remainder of the pipehne Include a survey of all below- to above-ground transition areas like the Bennett Street crossing Provide a detailed description of the critena to be used for the field evaluation(s) and prtontizatton of any mtegnty threats/anomalies that are identified Make the results oi any internai inspections, field excavations, and evaluahons available to PHMSA or its representative, (C) The performance of appropnate repairs or other corrective measures fully remediating all integrity threatening anomalies and condition(s) everywhere along the pipeline where such conditions are identified by the evaluation process Include a detailed description of the repair criteria and method(s) to be used in undertaking any repairs or other remedial actions, and (D) A proposed schedule for completion of the testing, evaluation, and repairs required by paragraphs (A)-(C) 6 Submit all plans and matenals to Director, Central Region, Pipehne and Hazardous Materials Safety Administration, 901 Locust Street, Suite 462, Kansas City, MO 64106- 2641 The plans must be revised as necessary to incorporate new information obtamed during the failure investigation testing, and remedial activities undertaken pursuant to this Order Submit any such plan revisions to the Director for pnor approval The Director may approve plan elements incrementally 7 Implement the plans as they are approved, including any plan revisions 8 Subnut reports to the Director, Central Region, PHMSA, on at least a quarterly basis that include the available data and results of the testing and evaluations required by this Order and descnbe the progress of the repairs or other remedial actions being undertaken The Director, Central Region, PHMSA may grant an extension of time for compliance with any of the terms ol this Order for good cause A request for an extension must be m wnting Respondent may appeal any decision of the Director, Central Region, PHMSA, to the Associate Admmistrator for Pipeline Safety Decisions of the Associate Admimstrator are final#

320065033h_corrective action order_03292006_text.pdf, page 7/ In accordance with 49 U S C ) 60122 and 49 C F R ss 190 223 failure to comply with this Order may result in the assessment of ctv&I penalties of not more than $100, 000 per day and in referral to the Attorney General for appropnate relief in a United States Distnct Court MAR 29 20, ", 6 Date Issued Stacey Gerar r Associate Ad ator for Pipeline Safety#

320065033H_Closure_03122013_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED March 12, 2013 Mr. Carl Ostach Vice President, Domestic Field Operations Buckeye Partners, LP 5 TEK Park 9999 Hamilton Blvd. Breinigsville, Pennsylvania 18031 Mr. Steve Pankhurst President BP Pipelines (North America) Inc. 150 West Warrenville Road Naperville, Illinois 60563 CPF 3-2006-5033H Dear Misters Ostach and Pankhurst: On March 29, 2006, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to BP Pipelines (North America) Inc. a Corrective Action Order in the above-referenced case. This Order included a requirement to take corrective actions on your pipeline. Buckeye Partners, LP became operator of the West Toledo pipeline on February 1, 2012. Based on our review of the documentation you provided, it has been determined that you have complied with the terms of this Order. Accordingly, this case is now closed and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, David Barrett Director, Central Region Pipeline and Hazardous Materials Safety Administration#