# BRAVO PIPELINE COMPANY — Notice of Probable Violation **Citation:** CPF 420205015 **Type / status:** enforcement / historical **Agency:** Pipeline and Hazardous Materials Safety Administration **Effective:** Not stated **Published:** 2020-10-27 CLOSED notice of probable violation citing 195.571, 195.589(c). ## Document text Notice of Probable Violation involving BRAVO PIPELINE COMPANY. PHMSA's enforcement data identifies the cited regulations as 195.571, 195.589(c). The case was opened on 2020-10-27 and is reported as closed as of 2022-01-14. Proposed civil penalty: $105,500. Assessed civil penalty: $81,300. Open the official case record for notices, responses, orders, and the latest status. Official case documents: 420205015_ NOPV PCP PCO_10272020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205015/420205015_%20NOPV%20PCP%20PCO_10272020.pdf 420205015_ NOPV PCP PCO_10272020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205015/420205015_%20NOPV%20PCP%20PCO_10272020_text.pdf 420205015_Final Order_12222021_(17-158457S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205015/420205015_Final%20Order_12222021_(17-158457S).pdf 420205015_Final Order_12222021_(17-158457S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205015/420205015_Final%20Order_12222021_(17-158457S)_text.pdf 420205015_Operator Response to Notice_02252021.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205015/420205015_Operator%20Response%20to%20Notice_02252021.pdf 420205015_ NOPV PCP PCO_10272020_text.pdf NOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER ELECTRONIC MAIL - RETURN RECEIPT REQUESTED October 27, 2020 Robert Peterson Senior Vice President and Chief Financial Officer Occidental Petroleum Corporation 5 Greenway Plaza Houston, Texas 77046 CPF 4-2020-5015 Dear Mr. Peterson: From January 22, 2018 through May 4, 2018, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Occidental Petroleum’s (OXY) Bravo CO2 Pipeline System in Sundown, Texas. As a result of the inspection, it is alleged that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable violations are: 1. § 195.571 What criteria must I use to determine the adequacy of cathodic protection? Cathodic protection required by this subpart must comply with one or more of the applicable criteria and other considerations for cathodic protection contained paragraphs 6.2.2, 6.2.3, 6.2.4, 6.2.5 and 6.3 in NACE SP 0169 (incorporated by reference, see § 195.3). 2 OXY failed to comply with the cathodic protection criteria required by § 195.571, which states that cathodic protection required by Subpart H must comply with one or more of the applicable criteria in addition to other considerations included in the incorporated by reference NACE SP 0169. In accordance with NACE SP 0169, OXY’s corrosion control procedures require a criterion of a negative (cathodic) potential of at least 850 millivolts with cathodic protection current applied, with consideration given to voltage drops other than those across the pipe-to-soil boundary. Based on the inspector’s review of annual readings (three years of pipe to soil readings from 2015-2017), OXY failed to meet the established criteria in both NACE SP 0169 and the operator’s corrosion control procedures for the following pipeline segments: ROW Code/Pipe Milepost IR Free Reading In Volts (Year) Bravo Slaughter-Anton 8" CO2 46.190 -.782V (2015), -.795V (2016), & -.809V (2017) 46.611 -.835V (2015), -.812V (2016), & -.806V (2017) 46.792 -.832V (2015), -.768V (2016), & -.764V (2017) 46.970 -.778V (2015), -.717V (2016), & -.715V (2017) Bravo Dome Station 0.000A -.741V (2015), -.692V (2016), & -.699V (2017) 0.000B -.761V (2015), -.776V (2016), & -.726V (2017) 0.000C -.752V (2015), -.802V (2016), & -.748V (2017) 0.000D -.715V (2015), -.758V (2016), & -.738V (2017) 0.000E -.689V (2015), -.740V (2016), & -.710V (2017) 0.000F -.705V (2015), -.727V (2016), & -.719V (2017) 0.000G - .609V (2015), -.650V (2016), & -.637V (2017) 0.000H -.690V (2015), -.710V (2016), & -.748V (2017) 0.000I -.564V (2015), -.564V (2016), & -.630V (2017) 0.000J -.630V (2015), -.639V (2016), & -.648V (2017) Bravo 20” CO2 Line 0.010 -.752V (2015), -.661V (2016) 1.340 -.731V (2015) & -.727V (2016) 2.910 -.719V (2015) & -.716V (2016) 4.340 -.728V (2015) & -.746V (2016) 5.310 -.722V (2015) & -.717V (2016) 6.920 -.729V (2015) & -.738V(2016) 7.940 -.754V (2015) & -.766V (2016) 9.020 -.752V (2015) & -.757V (2016) 10.960 -.727V (2015) & -.792V (2016) 15.300 -.719V (2015) & -.794V (2016) 17.510 -.714V (2015) & -.733V (2016) 19.850 -.737V (2015) & -.741V (2016) 22.870 -.759V (2015) & -.770V (2016) 24.780 -.764V (2015) & -.796V (2016) 25.760 -.770V (2015) & -.782V (2016) 27.270 -.808V (2015) & -.805V (2016) Sheep Mountain/OMS to Johnson Mesa 3.500 -.828V (2015) & -.827V (2016) 3.950 -.840V (2015) & -.822V (2016) 13.200 -.748V (2015) & -.792V (2016) 3 The above information was sourced from the Bravo Pipeline All Test Stations Report 2015-2017 and Sheep Mountain Pipeline All Test Stations Report 2015-2017. The operator did not provide any subsequent documentation to the inspector demonstrating remediation or that cathodic protection criteria was met for the identified test stations listed above. 2. § 195.589 What corrosion control information do I have to maintain? (c) You must maintain a record of each analysis, check, demonstration, examination, inspection, investigation, review, survey, and test required by this subpart in sufficient detail to demonstrate the adequacy of corrosion control measures or that corrosion requiring control measures does not exist. You must retain these records for at least 5 years, except that records related to § 195.569, § 195.573(a) and (b), and § 195.579(b)(3) and (c) must be retained for as long as the pipeline remains in service. OXY failed to maintain its Bravo CO2 Pipeline records in sufficient detail to demonstrate the adequacy of corrosion control measures. Specifically, the operator’s atmospheric corrosion inspection reports for the years 2014 and 2017 failed to document that timely atmospheric corrosion remediation occurred after pipeline and components were inspected for atmospheric corrosion. The Sheep Mountain Seminole Station 2014 atmospheric corrosion inspection forms (Bravo CO2 Pipeline Form PI-0750a) identified several items that required atmospheric corrosion maintenance and repair; however, OXY provided no subsequent documentation demonstrating remediation for the reported items. In subsequent communication between the operator and the inspector, the operator provided documentation demonstrating remediation of the atmospheric corrosion issues identified during the 2014 and 2017 atmospheric corrosion inspections. Proposed Civil Penalty Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679. For violation occurring on or after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of violations. We have reviewed the circumstances and supporting documentation involved for the above probable violations and has recommended that you be preliminarily assessed a civil penalty of $105,500 as follows: Item number PENALTY 1 $105,500 4 Proposed Compliance Order With respect to item 1 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Occidental Petroleum. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Warning Item With respect to item 2, we have reviewed the circumstances and supporting documents involved in this case and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to promptly correct this item. Failure to do so may result in additional enforcement action. Response to this Notice 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. All material you submit in response to this enforcement action may be 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, or request a hearing under 49 CFR § 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 without further notice to you and to issue a Final Order. If you are responding to this Notice, we propose that you submit your correspondence to my office within 30 days from receipt of this Notice. This period may be extended by written request for good cause. In your correspondence on this matter, please refer to CPF 4-2020-5015 and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Enforcement Proceedings 5 PROPOSED COMPLIANCE ORDER 1. 2. Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Occidental Petroleum a Compliance Order incorporating the following remedial requirements to ensure the compliance of Occidental Petroleum with the pipeline safety regulations: In regard to Item Number 1 of the Notice pertaining to Occidental Petroleum’s failure to comply with the cathodic protection criteria required by § 195.571 for portions of the Bravo CO2 Pipeline system, Occidental Petroleum must provide documentation that demonstrates that the Bravo CO2 Pipeline system is in compliance with 49 CFR §195.571. This demonstration must include those pipe-to-soil test points specifically listed in the table of this letter meeting criteria and must be submitted to Mary McDaniel, Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. Occidental Petroleum must comply with this item within 180 days following receipt of the Final Order. It is requested (not mandated) that Occidental Petroleum maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Mary McDaniel, Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. 420205015_Final Order_12222021_(17-158457S)_text.pdf December 22, 2021 VIA ELECTRONIC MAILT TO: robert peterson@oxy.com Mr. Robert Peterson Senior Vice President and Chief Financial Officer Occidental Petroleum Corporation 5 Greenway Plaza Houston, Texas 77046 Re: CPF No. 4-2020-5015 Dear Mr. Peterson: Enclosed please find the Final Order issued in the above-referenced case. It makes a finding of violation and assesses a reduced civil penalty of $81,300. It further finds that Bravo Pipeline Company, a subsidiary of Occidental Petroleum Corporation, has completed the actions specified in the Notice to comply with the pipeline safety regulations. When the civil penalty has been paid, this enforcement action will be closed. Service of the Final Order by e-mail is effective upon the date of transmission as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure cc: Ms. Mary McDaniel, PE, Director, Southwest Region, Office of Pipeline Safety, PHMSA Mr. Vishal Gupta, President and General Manager, Permian EOR, Occidental Petroleum Corporation, vishal_gupta@oxy.com Mr. Bradley Holland, Bravo Pipeline Company, Pipeline Operations Lead, bradley_holland@oxy.com CONFIRMATION OF RECEIPT REQUESTED U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ________________________________________________ In the Matter of ) ) ) Bravo Pipeline Company, a subsidiary of Occidental Petroleum Corporation, ) ) Respondent. ) ________________________________________________) ) CPF No. 4-2020-5015 FINAL ORDER From January 22, 2018 through May 4, 2018, pursuant to 49 U.S.C. § 60117, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and records of Bravo Pipeline Company, a subsidiary of Occidental Petroleum Corporation (OXY or Respondent) in Colorado, New Mexico, and Texas. The Bravo pipeline system consists of two PHMSA- regulated pipelines, the Bravo Pipeline (465 miles), and the Sheep Mountain Pipeline (408 miles), which deliver CO2 from Colorado and New Mexico to CO2 enhanced oil recovery (EOR) fields in the Permian Basin of West Texas and eastern New Mexico. As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to Respondent, by letter dated October 27, 2020, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that OXY had violated 49 C.F.R. § 195.571, proposed assessing a civil penalty of $105,500 for the alleged violation, and proposed ordering Respondent to take certain measures to correct the alleged violation. The Notice also included an additional warning item pursuant to 49 C.F.R. § 190.205, which required no further action, but warned the operator to correct the probable violation or face possible future enforcement action. After requesting and receiving an extension of time to respond, OXY responded to the Notice by letter dated February 25, 2021 (Response). OXY contested the allegation, offered additional information in response to the Notice, and requested that the proposed civil penalty be reduced or eliminated. Respondent did not request a hearing and therefore has waived its right to one. FINDING OF VIOLATION The Notice alleged that Respondent violated 49 C.F.R. Part 195.571, as follows: CPF No. 4-2020-5015 Page 2 Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.571, which states: § 195.571 What criteria must I use to determine the adequacy of cathodic protection? Cathodic protection required by this subpart must comply with one or more of the applicable criteria and other considerations for cathodic protection contained paragraphs 6.2.2, 6.2.3, 6.2.4, 6.2.5 and 6.3 in NACE SP 0169 (incorporated by reference, see § 195.3). The Notice alleged that Respondent violated 49 C.F.R. § 195.571 by failing to comply with the cathodic protection criteria required by § 195.571, which states that cathodic protection required by Subpart H must comply with one or more of the applicable criteria in addition to other considerations included in the incorporated by reference NACE SP 0169. Specifically, the Notice alleged that OXY failed to meet the established criteria (a negative (cathodic) potential of at least 850 millivolts with cathodic protection current applied, with consideration given to voltage drops other than those across the pipe-to-soil boundary) in both NACE SP 0169 and the operator’s corrosion control procedures for 47 separate pipeline segments across its Bravo pipeline system. Based on a review of the OXY’s annual surveys (three years of pipe to soil readings from 2015-2017), PHMSA alleged that OXY’s records showed at least 33 test stations that failed to meet the specified criterion for at least two consecutive annual surveys (2015 and 2016), and in some instances three consecutive annual surveys (2015, 2016, and 2017). In its Response, OXY contested that allegation of violation and stated that it “promptly and diligently worked to take corrective action and that at all times, Oxy maintained adequate cathodic protection in its pipeline system in accordance with 49 CFR 195.571.”1 OXY stated that after observing readings less negative than the -850mV ‘on’ criteria during an annual cathodic protection survey in November of 2015 for the Bravo pipeline system, it immediately increased the current output from the Bravo Dome rectifier in an attempt to increase potentials.2 After allowing time for polarization and observing no response to the actions taken to increase the potentials, OXY claims that it took the following additional actions: (1) Increased the current output from multiple influencing rectifiers (Bravo dome and MLV3) on the pipeline in 2016; (2) Electrically isolated the Bravo Dome rectifier current from the station piping; (3) Acquired and installed two additional rectifiers on the Bravo Dome and 8” Anton pipeline segments in 2017- 2018; (4) Conducted a depolarization survey and applied the 100mV polarization criterion to demonstrate that there was adequate cathodic protection on the pipelines in the third quarter of 2017; (5) Reviewed two inline inspection (ILI) assessments from 2012 and 2017, which found very minor corrosion along the entire pipeline, and specifically in and near where the low cathodic protection potentials were observed; and (6) at locations along the pipeline not meeting the polarized potential of -850 mV (instant-off), OXY maintained the 2018 planned rectifier installations during the second quarter of 2018 and permanently isolated the existing Bravo Dome rectifier to solely protect the Bravo Dome station.3 These actions resulted in the pipelines 1 Response, at 1. 2 Id. at 2. 3 Id. at 2-3. CPF No. 4-2020-5015 Page 3 being cathodically protected by the new MLV2, MP 46.9 and existing MLV3 rectifiers only. According to OXY, the 2018, 2019 and 2020 subsequent annual cathodic protection surveys showed that all potentials were more negative than the -850 mV ‘on’ criteria required by the NACE and OXY standards.4 Although OXY took documented steps to achieve compliance with the regulation and its own procedures, as outlined above, there is no dispute that OXY failed to achieve the -850mV criterion for 47 separate pipeline segments across its Bravo pipeline system between 2015 and 2017. OXY’s annual survey records for 2015, 2016, and 2017 showed that the -850 mV cathodic protection criteria specified by its procedures had not been met for the 33 test stations identified in the Notice, and OXY does not dispute this fact. In addition, the record contains no evidence to show that OXY considered IR drop in determining the adequacy of the cathodic protection, as required by the Part 195 referenced standard and its own procedures. OXY argues that it had met the 100mV polarization criterion allowed by NACE SP 0169; however, the operator’s own procedures specified only the use of the -850mV criterion with consideration of IR drop. OXY did not have procedures in place for using the 100mV criterion, and its procedures specifically stated that the -850mV criterion would be used. In sum, it is undisputed that OXY had recorded low annual cathodic protection survey potentials on the identified segments for 2015, 2016, and 2017 using the specified -850mV criterion, in violation of the regulation and its own procedures. Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R. § 195.571 by failing to meet the established criteria in both NACE SP 0169 and the operator’s corrosion control procedures. This finding of violation will be considered a prior offense in any subsequent enforcement action taken against Respondent. ASSESSMENT OF PENALTY Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed $200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any related series of violations.5 In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature, circumstances, and gravity of the violation, including adverse impact on the environment; the degree of Respondent’s culpability; the history of Respondent’s prior offenses; any effect that the penalty may have on its ability to continue doing business; the good faith of Respondent in attempting to comply with the pipeline safety regulations; and self-disclosure or actions to correct a violation prior to discovery by PHMSA. In addition, I may consider the economic benefit gained from the violation without any reduction 4 Id., at 3. 5 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223. CPF No. 4-2020-5015 Page 4 because of subsequent damages, and such other matters as justice may require. The Notice proposed a total civil penalty of $105,500 for the violation cited above. Item 1: The Notice proposed a civil penalty of $105,500 for Respondent’s violation of 49 C.F.R. § 195.571, for failing to meet the established criteria in both NACE SP 0169 and the operator’s corrosion control procedures on 47 separate pipeline segments across its Bravo pipeline system. In addition to the defenses outlined above, OXY attempts to mitigate the noncompliance by stating that it reviewed two Magnetic Flux Leakage (MFL) in-line inspections (ILI) that were performed in 2012 and 2017 to determine if there were indications of external corrosion as a result of its cathodic protection deficiencies. OXY claimed that there were only minor indications of corrosion from these ILI runs. Although I rejected OXY’s argument that the actions it took in an effort to remediate the deficiencies with its cathodic protection system warranted a withdrawal of the alleged violation, I do find that the actions constitute a basis for reducing the civil penalty under the culpability factor. While the actions taken by OXY did not remediate the deficiencies prior to the inspection, it is undisputed that OXY found the problem and took documented steps to correct it prior to PHMSA’s inspection. As such, OXY should be given credit for these actions when assessing the operators’ culpability for purposes of calculating a civil penalty in this case. I do not agree that performance of ILI in 2012 and 2017 would constitute a basis to further reduce the proposed civil penalty in this case. The performance of a 2012 ILI would not indicate corrosion from cathodic protection deficiencies in 2015, 2016, and 2017. In addition, external corrosion is a time-dependent threat and the specific environment and circumstances of the pipeline determines the rate of corrosion, and even minor indications of corrosion detected in 2017 may have resulted from the cathodic protection deficiencies. With regard to the other civil penalty criteria that I am required to assess, I find that PHMSA met its burden. The annual cathodic protection readings recorded show that OXY failed to comply with the applicable cathodic protection criteria required by the operator’s own corrosion control procedures, § 195.571, and NACE SP 0169. This was the case for at least two consecutive annual surveys, and in some instances three consecutive years for the test stations identified in the Notice. Additionally, the measures discussed in OXY’s Response provide no reasonable justification for why the operator failed to comply with the requirement. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a reduced civil penalty of $81,300 for a violation of 49 C.F.R. § 195.571. Payment of the civil penalty must be made within 20 days of service. Federal regulations (49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal Reserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed instructions are contained in the enclosure. Questions concerning wire transfers should be directed to: Financial Operations Division (AMK-325), Federal Aviation Administration, Mike Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City, Oklahoma 79169. The Financial Operations Division telephone number is (405) 954-8845. Failure to pay the $81,300 civil penalty will result in accrual of interest at the current annual rate CPF No. 4-2020-5015 Page 5 in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23. Pursuant to those same authorities, a late penalty charge of six percent (6%) per annum will be charged if payment is not made within 110 days of service. Furthermore, failure to pay the civil penalty may result in referral of the matter to the Attorney General for appropriate action in a district court of the United States. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Item 1 in the Notice for a violation of 49 C.F.R. § 195.571. Under 49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. The Director indicates that Respondent has taken the following actions specified in the proposed compliance order: 1. With respect to the violation of § 195.571 (Item 1), the Respondent provided annual cathodic protection survey records for 2018 and 2019 showing that the pipeline has achieved adequate cathodic protection in accordance with § 195.571, and NACE SP 0169. Accordingly, I find that compliance has been achieved with respect to this violation. Therefore, the compliance terms proposed in the Notice are not included in this Order. WARNING ITEM With respect to Item 2, the Notice alleged probable violation of Part 195, but identified it as a warning item pursuant to § 190.205. The warning was for: 49 C.F.R. § 195.589(c) (Item 2) ─ Respondent’s alleged failure to maintain its Bravo CO2 Pipeline records in sufficient detail to demonstrate the adequacy of corrosion control measures. OXY presented information in its Response showing that it had taken certain actions to address the cited items. If OPS finds a violation of this provision in a subsequent inspection, Respondent may be subject to future enforcement action. Under 49 C.F.R. § 190.243, Respondent may submit a Petition for Reconsideration of this Final Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address, no later than 20 days after receipt of service of the Final Order by Respondent. Any petition submitted must contain a brief statement of the issue(s) and meet all other requirements of 49 C.F.R. § 190.243. The filing of a petition automatically stays the payment of any civil penalty assessed. The other terms of the order, including any corrective action, remain in effect unless the Associate Administrator, upon request, grants a stay. If Respondent submits payment of the civil penalty, the Final Order becomes the final CPF No. 4-2020-5015 Page 6 administrative decision and the right to petition for reconsideration is waived. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. December 22, 2021 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety ## Provenance - Official: Yes - Source: - Source ID: `phmsa-enforcement` - SHA-256: `2af9ae52bc8360886d1988edda137090dc288d1c48de6d7a7673f8bb9bc8c728` - Retrieved: 2026-08-20T04:44:44.458Z - Exported: 2026-08-23T17:46:34.617Z - Document slug: `phmsa-enforcement-420205015` ### Source metadata ```json { "cpf": "420205015", "operator": "BRAVO PIPELINE COMPANY", "region": "Southwest", "pipelineType": "INTERSTATE LIQUID ONSHORE", "caseStatus": "CLOSED", "citedSections": [ "195.571", "195.589(c)" ], "dataAsOf": "08/04/2026 12PM", "caseDataAsOf": "2026-08-04", "attachmentCount": 5, "attachments": [ { "name": "420205015_ NOPV PCP PCO_10272020.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/420205015/420205015_%20NOPV%20PCP%20PCO_10272020.pdf", "bytes": 312475, "category": "agency_document" }, { "name": "420205015_ NOPV PCP PCO_10272020_text.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/420205015/420205015_%20NOPV%20PCP%20PCO_10272020_text.pdf", "bytes": 166778, "category": "agency_document" }, { "name": "420205015_Final Order_12222021_(17-158457S).pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/420205015/420205015_Final%20Order_12222021_(17-158457S).pdf", "bytes": 230595, "category": "agency_document" }, { "name": "420205015_Final Order_12222021_(17-158457S)_text.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/420205015/420205015_Final%20Order_12222021_(17-158457S)_text.pdf", "bytes": 149083, "category": "agency_document" }, { "name": "420205015_Operator Response to Notice_02252021.pdf", "url": "https://primis.phmsa.dot.gov/enforcement-documents/420205015/420205015_Operator%20Response%20to%20Notice_02252021.pdf", "bytes": 149889, "category": "party_submission" } ], "extractedAgencyDocumentCount": 2, "attachmentPolicy": "Official attachment links are retained. 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