{"operation":"document","citation":"CPF 52026009CAO","title":"PLAINS PIPELINE MIDCON LLC — Corrective Action Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2026-04-24","effective_on":null,"summary":"OPEN corrective action order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-52026009cao.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-52026009cao.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-52026009cao","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/52026009CAO","body":"Corrective Action Order involving PLAINS PIPELINE MIDCON LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2026-04-24 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n52026009CAO_Corrective Action Order (AMENDED)_05222026_(26-370329).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52026009CAO/52026009CAO_Corrective%20Action%20Order%20(AMENDED)_05222026_(26-370329).pdf\n\n52026009CAO_Corrective Action Order (AMENDED)_05222026_(26-370329)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52026009CAO/52026009CAO_Corrective%20Action%20Order%20(AMENDED)_05222026_(26-370329)_text.pdf\n\n52026009CAO_Corrective Action Order_04242026_(26-370329).pdf: https://primis.phmsa.dot.gov/enforcement-documents/52026009CAO/52026009CAO_Corrective%20Action%20Order_04242026_(26-370329).pdf\n\n52026009CAO_Corrective Action Order_04242026_(26-370329)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/52026009CAO/52026009CAO_Corrective%20Action%20Order_04242026_(26-370329)_text.pdf\n\n52026009CAO_Corrective Action Order_04242026_(26-370329)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, S.E.\nWashington, D.C. 20590\nApril 24, 2026\nVIA ELECTRONIC MAIL TO: patrick.hodgins@plains.com\nMr. Patrick Hodgins\nVice President, HSE, Comms. & Govt. Regulatory Affairs\nPlains Pipeline, L.P.\n333 Clay Street, Suite 1600\nHouston, TX 77002\nCPF No. 5-2026-009-CAO\nDear Mr. Hodgins:\nEnclosed please find a Corrective Action Order (CAO or Order) issued by the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), in the\nabove-referenced case. The CAO requires Plains Pipeline MidCon, LLC, a subsidiary of Plains\nPipeline, LP (Plains or Respondent), to take certain corrective actions with respect to the failures\nthat occurred on April 21, 2026, and April 23, 2026, on its Buffalo Pipeline System located in\nWoodard and Harper County, Oklahoma.\nService of the CAO by email is effective upon the date of transmission and acknowledgment of\nreceipt as provided under 49 CFR § 190.5. The terms and conditions of this Order are effective\nupon completion of service.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure: CAO\ncc: Dustin Hubbard, Director, Western Region, Office of Pipeline Safety, PHMSA\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 )\nPlains Pipeline MidCon, LLC, )\na subsidiary Plains Pipeline, LP, ) CPF No. 5-2026-009-CAO\n)\n)\nRespondent. )\n____________________________________)\nCORRECTIVE ACTION ORDER\nBackground and Purpose\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline\nSafety (OPS), is issuing this Corrective Action Order (CAO or Order) pursuant to the authority\nprovided in 49 U.S.C. § 60112. The CAO requires Plains Pipeline MidCon, LLC, a subsidiary of\nPlains Pipeline, LP (Plains or Respondent), to take certain necessary corrective actions to protect\nthe public, property, and the environment from the potential hazards associated with the\ncontinued operation of its Buffalo Pipeline System in Woodard and Harper County, Oklahoma,\nwhich recently experienced two failures and has a history of prior failures in 2024 and 2025.\nSpecifically, on April 21, 2026, Plains’ control room received a pipeline monitoring (PLM) alert\nindicating a product loss on the Buffalo Pipeline System between mainline valves BV-9 and BV-\n7. Plains responded by shutting down the line. Current estimates indicate that the failure led to\nthe release of approximately 520 barrels (bbls) of crude oil.\nTwo days later, on April 23, 2026, another failure occurred on the Buffalo Pipeline System\napproximately 50 miles from the earlier failure. This second failure occurred while Plains was\nrunning a cleaning pig through the pipeline as part of a planned repair. Initial estimates indicated\nthat the second failure, which Plains discovered after receiving a call from a landowner, led to\nthe release of 1 gallon of crude oil.\nPursuant to 49 U.S.C. § 60117, PHMSA has initiated an investigation of both failures. The\npreliminary findings of PHMSA’s ongoing investigation are as follows:\nPreliminary Findings\n• Plains operates a pipeline known as the Buffalo Pipeline System that spans 60.9 miles\nbetween the Orion Pump Station and the Stockholm Pump Station.\n\n\n\nCPF No. 5-2026-009-CAO\nPage 2\n• On April 21, 2026, Plains control room received a PLM alert indicating a pressure\ndrop in the Buffalo Pipeline System segment located between Orion Pump Station\nand Stockholm Pump Station. The release was confirmed at 9:20 am CDT (First\nFailure).\n• At 10:02 am CDT, Plains called the National Response Center and reported a crude\noil release of an unknown amount into a nearby water source.1\n• Initial estimates indicated approximately 410 bbls of crude oil was released. That\nnumber was updated on April 23, 2026, to 520 bbls of crude oil.\n• The First Failure occurred 75 feet from a water source (a nearby 2-foot-wide creek).\nCrude oil reached the creek and migrated approximately 2,500 feet to a natural pond.\n• Mitigation efforts consisted of booms installed downstream of the last oil indication\nand upstream towards the release location to prevent further migration. Two\nskimmers were installed in the creek and crews used vacuum trucks and hand tools to\nremove oil and environmental contamination. Contaminated ground is being\nexcavated between the failure point and the creek.\n• Prior to the accident, Plains personnel were in the area performing inline inspection\n(ILI) confirmation and remediation digs 1.5 miles upstream and downstream from the\nrelease location.\n• Previous ILI runs consisted of an MFL-A tool in 2024 and a UT tool in 2025.\n• Discussions with Plains personnel in the field indicated that the first failure location\nwas not indicated on the previous ILI run.\n• On April 23, 2026, at 10:25 am CDT, Plains identified another leak occurring at an\nanomaly dig site approximately 50 miles away from the initial leak (Second Failure).\nPlains identified the Second Failure while starting a pig run with subsequent plans for\na nitrogen purge. The site had been excavated, and the coating had already been\nremoved. The leak was called in by a nearby landowner.\n• The First Failure occurred at MP 16.4. The line at that location was constructed in\n1960 with a nominal diameter of 8.625 inches, wall thickness of 0.188 inches, X-52\nGrade, Low Frequency Electric Resistance Welded pipe, manufactured on an\nunknown date, from an unknown manufacturer, with a coal tar coating. MOP on the\npipe was established at 1250 psi in 2017 via a 2016 8 hour hydrotest. The pipe was\noperating under a pressure reduction to 600 psi at the time of failure.\n• The Second Failure was at Dig #61. The line at that location was constructed in 1960\nwith a nominal diameter of 8.625 inches, wall thickness of 0.188 inches, X-52 Grade,\nLow Frequency Electric Resistance Welded pipe, manufactured on an unknown date,\n1 National Response Center (NRC) Report # 1460291.\n\n\n\nCPF No. 5-2026-009-CAO\nPage 3\nfrom an unknown manufacturer, with a coal tar and shrink sleeve coating. MOP on\nthe pipe was established at 1250 psi in 2017 via a 2016 8 hour hydrotest. The pipe\nwas operating under a pressure reduction to 600 psi at the time of failure.\n• PHMSA is aware of several previous failures on the Buffalo Pipeline System. In July\nof 2025, two failures occurred that resulted in the release of 100 and 179 bbls of\ncrude oil, respectively. The cause of both failures was attributed to microbiologically\ninduced corrosion and under deposit corrosion.\n• On October 26, 2024, 200 bbls of crude oil was released on the same segment with\nthat failure also being attributed to microbiologically induced corrosion.\n• The 2024 and 2025 failures occurred on the Buffalo Pipeline System that spans 60.9\nmiles between the Orion Pump Station and the Stockholm Pump Station as part of the\nBuffalo Pipeline System.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nSection 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline\nfacility is or would be hazardous to life, property, or the environment and if there is a likelihood\nof serious harm, to expeditiously order the operator of the facility to take necessary corrective\naction, including suspended or restricted use of the facility, physical inspection, testing, repair,\nreplacement, or other appropriate action. An order issued expeditiously must provide an\nopportunity for a hearing as soon as practicable after the order is issued.\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the\ncharacteristics of the pipe and other equipment used in the pipeline facility, including the age,\nmanufacture, physical properties, and method of manufacturing, constructing, or assembling the\nequipment; (2) the nature of the material the pipeline facility transports, the corrosive and\ndeteriorative qualities of the material, the sequence in which the material is transported, and the\npressure required for transporting the material; (3) the aspects of the area in which the pipeline\nfacility is located, including climatic and geologic conditions and soil characteristics; (4) the\nproximity of the area in which the facility is located to environmentally sensitive areas; (5) the\npopulation density and population and growth patterns of the area in which the pipeline facility is\nlocated; (6) any recommendation of the National Transportation Safety Board made under\nanother law; and (7) any other factors PHMSA may consider as appropriate.\nAfter evaluating the foregoing preliminary findings of fact, and having considered the\ncharacteristics of the pipeline, the nature of the failures, the prior history of corrosion and\nfailures on the pipeline; the hazardous nature of the material transported (crude oil); the existing\nand potential additional impacts to life, property, or the environment; the still-unknown cause of\nthe Failures; and the possibility of additional failures on the pipeline system; it is hereby\ndetermined that continued operation of the Buffalo Pipeline System segment, as defined below,\nwithout corrective measures is or would be hazardous to life, property, or the environment, and\nthat failure to issue this Order expeditiously would result in the likelihood of serious harm.\n\n\n\nCPF No. 5-2026-009-CAO\nPage 4\nAccordingly, this Order mandating immediate corrective action is issued expeditiously without\nprior notice and opportunity for a hearing. The terms and conditions of this Order are effective\nupon completion of service.\nWithin 10 days of receipt of this Order, Respondent may request a hearing to be held as soon as\npracticable, by notifying the Associate Administrator for Pipeline Safety in writing, with a copy\nto the Director, PHMSA, OPS Western Region. If a hearing is requested, it will be held in\naccordance with 49 CFR § 190.211.\nAfter receiving and analyzing additional data in the course of this investigation, PHMSA may\nidentify other corrective measures that need to be taken. Respondent will be notified of any\nadditional measures required and, if appropriate, PHMSA will consider a further amended order.\nTo the extent consistent with safety, Respondent will be afforded notice and an opportunity for a\nhearing prior to the imposition of any additional corrective measures.\nCorrective Measures\nDefinitions:\nDirector – The Director, Western Region, PHMSA, OPS.\nPipeline Segment – The 60.9 mile pipeline spanning from Orion Pump Station to Stockholm\nPump Station as part of the Buffalo Pipeline System located in Woodard County, Oklahoma.\n1. Shutdown of the Pipeline Segment. Respondent must shut down the Pipeline Segment\nimmediately upon issuance of this Order. The Pipeline Segment must remain shut-in and\nmay not be operated until authorized to be restarted by the Director in accordance with the\nterms of this Order.\n2. Review of Prior Inline Inspection Results. Within 60 days of issuance of this Order,\nRespondent must conduct a review of any previous inline inspection (ILI) results of the\nPipeline Segment. In its review, Respondent must re-evaluate all ILI results since 2015,\nincluding a review of the ILI vendors' raw data and analysis. Respondent must determine\nwhether any features were present near the Failure sites. Respondent must also determine\nif any features with similar characteristics are present elsewhere on the Pipeline Segment.\nRespondent must submit documentation of this ILI review to the Director within 60 days of\nissuance of this Order as follows:\na. List all ILI tool runs, tool types, and the calendar years of the tool runs.\nb. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures present on the failed pipe and other pipe removed.\nc. List, describe (type, size, wall loss, etc.), and identify the specific location of all ILI\nfeatures with similar characteristics present elsewhere on the Pipeline Segment.\nd. Explain the process used to review the ILI results and the results of the reevaluation.\ne. Conduct a review of all procedures and records related to Plains’ integrity assessment\n\n\n\nCPF No. 5-2026-009-CAO\nPage 5\nprogram when conducting ILIs in accordance with 49 CFR § 195.591.\n3. Mechanical and Metallurgical Testing. Within 45 days of issuance of this Order,\nRespondent must complete mechanical and metallurgical testing and failure analysis of the\nfailed pipe, an analysis of representative soil samples from the Failures locations and\nproduct transported in pipe at the time of the failures, and any foreign materials. The\ntesting must be conducted by an independent third-party acceptable to the Director.\nRespondent must complete the testing and analysis as follows:\na. Document the chain-of-custody when handling and transporting the failed pipe sections\nand other evidence from the Failure sites.\nb. Within 10 days of issuance of this Order, develop and submit the testing protocol and\nthe proposed testing laboratory to the Director for prior approval.\nc. Prior to beginning the mechanical and metallurgical testing, provide the Director with\nthe scheduled date, time, and location of the testing to allow for an OPS representative\nto witness the testing.\nd. Ensure the testing laboratory distributes all reports whether draft or final in their\nentirety to the Director at the same time they are made available to Respondent.\n4. Root Cause Failure Analysis. Within 90 days following issuance of this Order, complete a\nroot cause failure analysis (RCFA) and submit a final report of this RCFA to the Director.\nThe RCFA must be supplemented or facilitated by an independent third-party acceptable to\nthe Director and must document the decision-making process and all factors contributing to\nthe Failures, including potentially corrosive properties of the product or environment. The\nfinal report must include findings and any lessons learned and whether the findings and\nlessons learned are applicable to other locations within Respondent’s pipeline system.\n5. Remedial Work Plan.\na. Within 90 days following issuance of this Order, Respondent must submit a remedial\nwork plan (RWP) to the Director for approval.\nb. The Director may approve the RWP incrementally without approving the entire RWP.\nc. Once approved by the Director, the RWP will be incorporated by reference into this\nOrder.\nd. The RWP must specify the tests, inspections, assessments, evaluations, and remedial\nmeasures Respondent will use to verify the integrity of the Pipeline Segment. It must\naddress all known or suspected factors and causes of the Failures. Respondent must\nconsider the risks and consequences of another failure to develop a prioritized schedule\nfor RWP-related work along the Pipeline Segment.\ne. The RWP must include a procedure or process to:\ni. Gather all data necessary to review the failure history (in service and pressure test\nfailures) of the Pipeline Segment and to prepare a written report containing all the\navailable information such as the locations, dates, and causes of leaks and failures.\nii. Integrate the results of the metallurgical testing, root cause failure analysis, and other\n\n\n\nCPF No. 5-2026-009-CAO\nPage 6\ncorrective actions required by this Order with all relevant pre-existing operational\nand assessment data for the Pipeline Segment. Pre-existing operational data\nincludes, but is not limited to, design, construction, operations, maintenance, testing,\nrepairs, prior metallurgical analyses, and any third-party consultation information.\nPre-existing assessment data includes, but is not limited to, ILI tool runs, hydrostatic\npressure testing, direct assessments, inhibitor injection, corrosion coupon data or\nother internal corrosion prevention activities, close interval surveys, and\nDCVG/ACVG surveys.\niii. Determine if conditions similar to those contributing to the Failures are likely to\nexist elsewhere on the Pipeline Segment.\niv. Conduct additional field tests, inspections, assessments, and evaluations to determine\nwhether, and to what extent, the conditions associated with the Failures and other\nfailures from the failure history (see (e)(ii) above) or any other integrity threats are\npresent elsewhere on the Pipeline Segment. At a minimum, this process must\nconsider all failure causes and specify the use of one or more of the following:\n1) ILI tools that are technically appropriate for assessing the pipeline system based\non the cause of the Failures and that can reliably detect and identify anomalies;\n2) Hydrostatic pressure testing;\n3) Close-interval surveys;\n4) Cathodic protection surveys, to include interference surveys in coordination with\nother utilities/pipelines in the area;\n5) Coating surveys;\n6) Stress corrosion cracking surveys;\n7) Selective seam corrosion surveys; and\n8) Other tests, inspections, assessments, and evaluations appropriate for the failure\ncauses.\nv. Describe the inspection and repair criteria Respondent will use to prioritize,\nexcavate, evaluate, and repair anomalies, imperfections, and other identified\nintegrity threats. Include a description of how any defects will be graded and a\nschedule for repairs or replacement.\nvi. Based on the known history and condition of the Pipeline Segment, describe the\nmethods Respondent will use to repair, replace, or take other corrective measures\nto remediate the conditions associated with the Failures and to address other\nknown integrity threats along the Pipeline Segment. The repair, replacement, or\nother corrective measures must meet the criteria specified in (e)(vi) above.\nvii. Implement continuing long-term periodic testing and integrity verification\nmeasures to ensure the ongoing safe operation of the Pipeline Segment\n\n\n\nCPF No. 5-2026-009-CAO\nPage 7\nconsidering the results of the analyses, inspections, evaluations, and corrective\nmeasures undertaken pursuant to the Order.\nf. Include a proposed schedule for completion of the RWP.\ng. Respondent must revise the RWP as necessary to incorporate new information obtained\nduring the failure investigation and remedial activities, to incorporate the results of actions\nundertaken pursuant to this Order, and to incorporate modifications required by the\nDirector.\nh. Submit any plan revisions to the Director for prior approval. The Director may approve\nplan revisions incrementally. All revisions to the RWP after it has been approved and\nincorporated by reference into this Order will be fully described and documented in the\nCAO Documentation Report.\ni. Implement the RWP as it is approved by the Director, including any revisions to the plan.\n6. Restart Plan. Prior to resuming operation of the Pipeline Segment, develop and submit a\nwritten Restart Plan to the Director for prior approval.\na. The Director may approve the Restart Plan incrementally without approving the entire\nplan, but the Pipeline Segment cannot resume operation until the Restart Plan is\napproved in its entirety.\nb. Once approved by the Director, the Restart Plan will be incorporated by reference into\nthis Order.\nc. The Restart Plan must provide for adequate patrolling of the Pipeline Segment during\nthe restart process and must include incremental pressure increases during start up, with\neach increment to be held for at least two hours.\nd. The Restart Plan must include sufficient surveillance of the pipeline during each\npressure increment to ensure that no leaks are present when operation of the line\nresumes.\ne. The Restart Plan must specify a daylight restart and include advance communications\nwith local emergency response officials.\nf. The Restart Plan must provide for a review of the Pipeline Segment for conditions\nsimilar to those of the Failures including a review of construction, operating and\nmaintenance (O&M) and integrity management records such as ILI results, hydrostatic\ntests, root cause failure analysis of prior failures, aerial and ground patrols, corrosion,\ncathodic protection, excavations, and pipe replacements. Respondent must address any\nfindings that require remedial measures to be implemented prior to restart.\ng. The Restart Plan must also include documentation of the completion of all mandated\nactions, and a management of change plan to ensure that all procedural modifications\nare incorporated into Respondent’s O&M procedures manual.\nh. The Restart Plan must provide for hydrostatic pressure testing of the Pipeline Segment.\n\n\n\nCPF No. 5-2026-009-CAO\nPage 8\n7. Return to Service. After the Director approves the Restart Plan, Respondent may return\nthe Pipeline Segment to service in accordance with the approved Restart Plan, but the\noperating pressure must not exceed the pressure restrictions in accordance with this Order.\n8. Operating Pressure Restriction. In accordance with the terms of this Order, Respondent\nmust reduce and maintain no less than a twenty percent (20%) pressure reduction in the\nactual operating pressure along the entire length of the Pipeline Segment such that the\noperating pressure along the Pipeline Segment will not exceed eighty percent (80%) of the\nactual operating pressure in effect immediately prior to the Failures.\na. This pressure restriction is to remain in effect until written approval to increase the\npressure or return the pipeline to its pre-failure operating pressure is obtained from\nthe Director in accordance with the terms of this order.\nb. Within 10 days of receipt of this Order, Plains must provide the Director the actual\noperating pressures of each pump/compressor station on the Affected Segment at the\ntime of failure and the reduced pressure restriction set-points at these same locations.\nc. This pressure restriction requires any relevant remote or local alarm limits, software\nprogramming set-points or control points, and mechanical over-pressure devices to be\nadjusted accordingly.\nd. When determining the pressure restriction set-points, Respondent must take into\naccount any ILI features or anomalies present in the Pipeline Segment to provide for\ncontinued safe operation while further corrective actions are completed.\ne. Respondent must review the pressure restriction monthly by analyzing the operating\npressure data, taking into account any ILI features or anomalies present in the\nPipeline Segment. Respondent must immediately reduce the operating pressure\nfurther to maintain the safe operations of the Pipeline Segment, if warranted by the\nmonthly review. Further, Respondent must submit the results of the monthly review\nto the Director including, at a minimum, the current discharge set-points (including\nany additional pressure reductions), and any pressure exceedance at discharge set-\npoints. Submittals must be made quarterly, in accordance with the terms of this\nOrder.\n9. Removal of Pressure Restriction.\na. The Director may allow the removal or modification of the pressure restriction upon a\nwritten request from Respondent demonstrating that restoring the pipeline to its pre-\nfailure operating pressure is justified based on a reliable engineering analysis showing\nthat the pressure increase is safe considering all known defects, anomalies, and\noperating parameters of the pipeline.\nb. The Director may allow the temporary removal or modification of the pressure\nrestrictions upon a written request from Respondent demonstrating that temporary\nmitigative and preventive measures are implemented prior to and during the temporary\nremoval or modification of the pressure restriction. The Director's determination will\nbe based on the failures, causes, and evidence that preventative and mitigative actions\ntaken by the operator provide for the safe operation of the Pipeline Segment during the\ntemporary removal or modification of the pressure restriction. Appeals to\n\n\n\nCPF No. 5-2026-009-CAO\nPage 9\ndeterminations of the Director in this regard will be decided by the Associate\nAdministrator for Pipeline Safety.\n10. CAO Documentation Report. Respondent must create and revise, as necessary, a CAO\nDocumentation Report (CDR). When Respondent has concluded all the items in this\nOrder it will submit the final CDR in its entirety to the Director. This will allow the\nDirector to complete a thorough review of all actions taken by Respondent with regards\nto this Order prior to approving the closure of this Order. The intent is for the CDR to\nsummarize all activities and documentation associated with this Order in one document.\na. The Director may approve the CDR incrementally without approving the entire CDR.\nb. Once approved by the Director, the CDR will be incorporated by reference into this\nOrder.\nc. The CDR must include, but is not necessarily limited to, the following:\ni. Table of Contents;\nii. Summary of the Failures and the response activities;\niii. Summary of pipe data, material properties and all prior assessments of the Pipeline\nSegment;\niv. Summary of all tests, inspections, assessments, evaluations, and analysis required\nby the Order;\nv. Summary of the Mechanical and Metallurgical Testing as required by the Order;\nvi. Summary of the RCFA with all root causes as required by the Order;\nvii. Documentation of all actions taken by Respondent to implement the RWP, the\nresults of those actions, and the inspection and repair criteria used;\nviii. Documentation of any revisions to the RWP including those necessary to\nincorporate the results of actions undertaken pursuant to this Order and whenever\nnecessary to incorporate new information obtained during the failure investigation\nand remedial activities;\nix. Lessons learned while completing this Order;\nx. A path forward describing specific actions Respondent will take on its entire\npipeline system as a result of the lessons learned from work on this Order; and\nxi. Appendices (if required).\nOther Requirements:\n11. Approvals. With respect to each submission under this Order that requires the approval\nof the Director, the Director may: (a) approve, in whole or part, the submission; (b)\napprove the submission on specified conditions; (c) modify the submission to cure any\ndeficiencies; (d) disapprove in whole or in part, the submission, directing that Respondent\nmodify the submission, or (e) any combination of the above. In the event of approval,\napproval upon conditions, or modification by the Director, Respondent shall proceed to\ntake all action required by the submission as approved or modified by the Director. If the\n\n\n\nCPF No. 5-2026-009-CAO\nPage 10\nDirector disapproves all or any portion of the submission, Respondent must correct all\ndeficiencies within the time specified by the Director and resubmit it for approval.\n12. Extensions of Time. The Director may grant an extension of time for compliance with\nany of the terms of this Order upon a written request timely submitted demonstrating good\ncause for an extension.\n13. Reporting. Plains must submit quarterly reports to the Director that: (1) include all available data\nand results of the testing and evaluations required by this Order; and (2) describe the progress of\nthe repairs or other remedial actions being undertaken. The first quarterly report is due on May 29,\n2026. The Director may change the interval for the submission of these reports.\n14. Documentation of the Costs. It is requested that Respondent maintain documentation of\nthe costs associated with implementation of this CAO. Include in each quarterly report\nsubmitted the to-date total costs associated with: (1) preparation and revision of procedures,\nstudies, and analyses; (2) physical changes to pipeline infrastructure, including repairs,\nreplacements, and other modifications; and (3) environmental remediation, if applicable.\nBe advised that all material submitted in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. § 552(b), along with the complete original document you\nmust provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted information\nqualifies for confidential treatment under 5 U.S.C. § 552(b).\nIn your correspondence on this matter, please refer to “CPF No. 5-2026-009-CAO” and for each\ndocument you submit, please provide a copy in electronic format whenever possible. The\nactions required by this Order are in addition to and do not waive any requirements that apply to\nRespondent’s pipeline system under 49 CFR Parts 190 through 199, under any other order issued\nto Respondent under authority of 49 U.S.C. Chapter 601, or under any other provision of federal\nor state law.\nRespondent may appeal any decision of the Director to the Associate Administrator for Pipeline\nSafety. Decisions of the Associate Administrator shall be final.\nFailure to comply with this Order may result in the assessment of civil penalties and in referral to\nthe Attorney General for appropriate relief in United States District Court pursuant to 49 U.S.C.\n§ 60120. The terms and conditions of this Order are effective upon service in accordance with 49\nCFR § 190.5.\n_________________________________ ________________________\nLinda Daugherty Date Issued\nActing Associate Administrator\nfor Pipeline Safety\n\n52026009CAO_Corrective Action Order (AMENDED)_05222026_(26-370329)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n1200 New Jersey Avenue, S.E.\nWashington, D.C. 20590\nMay 22, 2026\nVIA ELECTRONIC MAIL TO: patrick.hodgins@plains.com\nMr. Patrick Hodgins\nVice President, HSE, Comms. & Govt. Regulatory Affairs\nPlains Pipeline, L.P.\n333 Clay Street, Suite 1600\nHouston, TX 77002\nCPF No. 5-2026-009-CAO\nDear Mr. Hodgins:\nEnclosed please find an Amended Corrective Action Order (ACAO or Order) issued by the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), in the above-referenced case. The ACAO amends certain preliminary findings and\ncorrective measures in the Corrective Action Order that was issued on April 24, 2026 for failures\non the Buffalo Pipeline System located in Woodard and Harper County, Oklahoma. Specifically,\nthe ACAO corrects the date and other information about the First Failure in the second and third\nbullets of the Preliminary Findings and removes the word compressor from paragraph 8,\nsubparagraph b of the Corrective Measures.\nService of the ACAO by email is effective upon the date of transmission and acknowledgment of\nreceipt as provided under 49 CFR § 190.5. The terms and conditions of this Order are effective\nupon completion of service.\nSincerely,\nLinda Daugherty\nActing Associate Administrator\nfor Pipeline Safety\nEnclosure: ACAO\ncc: Dustin Hubbard, Director, Western Region, Office of Pipeline Safety, PHMSA\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 )\nPlains Pipeline MidCon, LLC, )\na subsidiary Plains Pipeline, LP, ) CPF No. 5-2026-009-CAO\n)\n)\nRespondent. )\n____________________________________)\nAMENDED CORRECTIVE ACTION ORDER\nBackground and Purpose\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline\nSafety (OPS), is issuing this Amended Corrective Action Order (“ACAO” or “Order”)1 pursuant\nto the authority provided in 49 U.S.C. § 60112. The ACAO requires Plains Pipeline MidCon,\nLLC, a subsidiary of Plains Pipeline, LP (Plains or Respondent), to take certain necessary\ncorrective actions to protect the public, property, and the environment from the potential hazards\nassociated with the continued operation of its Buffalo Pipeline System in Woodard and Harper\nCounty, Oklahoma, which recently experienced two failures and has a history of prior failures in\n2024 and 2025.\nSpecifically, on April 20, 2026, Plains’ control room received a pipeline monitoring (PLM) alert\nindicating a product loss on the Buffalo Pipeline System between mainline valves BV-9 and BV-\n7. Plains responded by shutting down the line. Current estimates indicate that the failure led to\nthe release of approximately 520 barrels (bbls) of crude oil.\nTwo days later, on April 23, 2026, another failure occurred on the Buffalo Pipeline System\napproximately 50 miles from the earlier failure. This second failure occurred while Plains was\nrunning a cleaning pig through the pipeline as part of a planned repair. Initial estimates indicated\nthat the second failure, which Plains discovered after receiving a call from a landowner, led to\nthe release of 1 gallon of crude oil.\n1 To the extent this ACAO is modified from the original CAO issued to Respondent under CPF No. 5-2026-009-\nCAO on April 24, 2026, this ACAO supersedes and replaces the original CAO. To the extent this ACAO is\nunmodified from the original CAO, this ACAO retains the full force and effect of the original CAO. All deadlines\nnoted in the order which refer to the date “this Order is issued” or “receipt of this Order” refer to the issuance of the\noriginal CAO on April 24, 2026.\n\n\n\nCPF No. 5-2026-009-CAO\nPage 2\nPursuant to 49 U.S.C. § 60117, PHMSA has initiated an investigation of both failures. The\npreliminary findings of PHMSA’s ongoing investigation are as follows:\nPreliminary Findings\n• Plains operates a pipeline known as the Buffalo Pipeline System that spans 60.9 miles\nbetween the Orion Pump Station and the Stockholm Pump Station.\n• On April 20, 2026, Plains control room received a PLM alert indicating a product loss\nin the Buffalo Pipeline System segment located between Orion Pump Station and\nStockholm Pump Station. The release was confirmed on April 21, 2026 at 9:20 am\nCDT (First Failure).\n• On April 21, 2026 at 10:02 am CDT, Plains called the National Response Center and\nreported a crude oil release of an unknown amount into a nearby water source.2\n• Initial estimates indicated approximately 410 bbls of crude oil was released. That\nnumber was updated on April 23, 2026, to 520 bbls of crude oil.\n• The First Failure occurred 75 feet from a water source (a nearby 2-foot-wide creek).\nCrude oil reached the creek and migrated approximately 2,500 feet to a natural pond.\n• Mitigation efforts consisted of booms installed downstream of the last oil indication\nand upstream towards the release location to prevent further migration. Two\nskimmers were installed in the creek and crews used vacuum trucks and hand tools to\nremove oil and environmental contamination. Contaminated ground is being\nexcavated between the failure point and the creek.\n• Prior to the accident, Plains personnel were in the area performing inline inspection\n(ILI) confirmation and remediation digs 1.5 miles upstream and downstream from the\nrelease location.\n• Previous ILI runs consisted of an MFL-A tool in 2024 and a UT tool in 2025.\n• Discussions with Plains personnel in the field indicated that the first failure location\nwas not indicated on the previous ILI run.\n• On April 23, 2026, at 10:25 am CDT, Plains identified another leak occurring at an\nanomaly dig site approximately 50 miles away from the initial leak (Second Failure).\nPlains identified the Second Failure while starting a pig run with subsequent plans for\na nitrogen purge. The site had been excavated, and the coating had already been\nremoved. The leak was called in by a nearby landowner.\n2 National Response Center (NRC) Report # 1460291.\n\n\n\nCPF No. 5-2026-009-CAO\nPage 3\n• The First Failure occurred at MP 16.4. The line at that location was constructed in\n1960 with a nominal diameter of 8.625 inches, wall thickness of 0.188 inches, X-52\nGrade, Low Frequency Electric Resistance Welded pipe, manufactured on an\nunknown date, from an unknown manufacturer, with a coal tar coating. MOP on the\npipe was established at 1250 psi in 2017 via a 2016 8 hour hydrotest. The pipe was\noperating under a pressure reduction to 600 psi at the time of failure.\n• The Second Failure was at Dig #61. The line at that location was constructed in 1960\nwith a nominal diameter of 8.625 inches, wall thickness of 0.188 inches, X-52 Grade,\nLow Frequency Electric Resistance Welded pipe, manufactured on an unknown date,\nfrom an unknown manufacturer, with a coal tar and shrink sleeve coating. MOP on\nthe pipe was established at 1250 psi in 2017 via a 2016 8 hour hydrotest. The pipe\nwas operating under a pressure reduction to 600 psi at the time of failure.\n• PHMSA is aware of several previous failures on the Buffalo Pipeline System. In July\nof 2025, two failures occurred that resulted in the release of 100 and 179 bbls of\ncrude oil, respectively. The cause of both failures was attributed to microbiologically\ninduced corrosion and under deposit corrosion.\n• On October 26, 2024, 200 bbls of crude oil was released on the same segment with\nthat failure also being attributed to microbiologically induced corrosion.\n• The 2024 and 2025 failures occurred on the Buffalo Pipeline System that spans 60.9\nmiles between the Orion Pump Station and the Stockholm Pump Station as part of the\nBuffalo Pipeline System.\nDetermination of Necessity for Corrective Action Order and Right to Hearing\nSection 60112 of title 49, United States Code, authorizes PHMSA to determine that a pipeline\nfacility is or would be hazardous to life, property, or the environment and if there is a likelihood\nof serious harm, to expeditiously order the operator of the facility to take necessary corrective\naction, including suspended or restricted use of the facility, physical inspection, testing, repair,\nreplacement, or other appropriate action. An order issued expeditiously must provide an\nopportunity for a hearing as soon as practicable after the order is issued.\nIn deciding whether to issue an order, PHMSA must consider the following, if relevant: (1) the\ncharacteristics of the pipe and other equipment used in the pipeline facility, including the age,\nmanufacture, physical properties, and method of manufacturing, constructing, or assembling the\nequipment; (2) the nature of the material the pipeline facility transports, the corrosive and\ndeteriorative qualities of the material, the sequence in which the material is transported, and the\npressure required for transporting the material; (3) the aspects of the area in which the pipeline\nfacility is located, including climatic and geologic conditions and soil characteristics; (4) the\nproximity of the area in which the facility is located to environmentally sensitive areas; (5) the\npopulation density and population and growth patterns of the area in which the pipeline facility is\n\n\n\nC","truncated":true,"body_characters":60810}