# NOBLE MIDSTREAM SERVICES, LLC — Warning Letter

**Citation:** CPF 520176028W  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2017-08-10

CLOSED warning letter citing 194.101(a).

## Document text

Warning Letter involving NOBLE MIDSTREAM SERVICES, LLC. PHMSA's enforcement data identifies the cited regulation as 194.101(a). The case was opened on 2017-08-10 and is reported as closed as of 2017-08-10. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520176028W_Warning Letter_08102017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176028W/520176028W_Warning%20Letter_08102017.pdf

520176028W_Warning Letter_08102017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520176028W/520176028W_Warning%20Letter_08102017_text.pdf

520176028W_Warning Letter_08102017_text.pdf

WARNING LETTER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
August 10, 2017
Mr. Terry Gerhart
Chief Executive Officer
Noble Midstream Services, LLC
1001 Noble Energy Way
Houston, TX 77070
CPF 5-2017-6028W
Dear Mr. Gerhart:
On December 12 through 15, 2016, representatives of the Pipeline and Hazardous Materials
Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code,
inspected your Wells Ranch Pipeline in Weld County, Colorado.
As a result of the inspection, it is alleged that you have committed a probable violation of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item
inspected and the probable violation is:
1. §194.101 Operators required to submit plans.
(a) Except as provided in paragraph (b) of this section, unless OPS grants a
request from an Federal On-Scene Coordinator (FOSC) to require an operator of
a pipeline in paragraph (b) to submit a response plan, each operator of an
onshore pipeline facility shall prepare and submit a response plan to PHMSA as
provided in §194.119. A pipeline which does not meet the criteria for significant
and substantial harm as defined in §194.103(c) and is not eligible for an exception
under §194.101(b), can be expected to cause substantial harm. Operators of
substantial harm pipeline facilities must prepare and submit plans to PHMSA for
review.



During the inspection of your records, no Facility Response Plan (FRP) was provided to
demonstrate that the plan was submitted to PHMSA for review in accordance with
§194.101(a). At the time of the inspection, it was determined that an FRP was required for
your Wells Ranch Pipeline system in Weld County, Colorado. Subsequently, a copy of an
email dated 2/24/17 from PHMSA was provided to indicate your FRP sequence #3064.
As of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a
civil penalty not to exceed $209,002 per violation per day the violation persists up to a
maximum of $2,090,022 for a related series of violations. 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 correct the item identified in this letter. Failure to do so will result in Noble
Midstream Services, LLC being subject to additional enforcement action.
No reply to this letter is required. If you choose to reply, in your correspondence please refer
to CPF 5-2017-6028W. 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).
Sincerely,
Kim West
Acting Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 J. Coleman (#154542)
2

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/520176028W>
- Source ID: `phmsa-enforcement`
- SHA-256: `f9c381749fcc36227d6ce29d1d1c51cca39bd2c036058b3a51b832a923fe8ff9`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T15:25:34.009Z
- Document slug: `phmsa-enforcement-520176028w`

### Source metadata

```json
{
  "cpf": "520176028W",
  "operator": "NOBLE MIDSTREAM SERVICES, LLC",
  "region": "Western",
  "pipelineType": "INTRASTATE LIQUID ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "194.101(a)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 2,
  "attachments": [
    {
      "name": "520176028W_Warning Letter_08102017.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520176028W/520176028W_Warning%20Letter_08102017.pdf",
      "bytes": 81135,
      "category": "agency_document"
    },
    {
      "name": "520176028W_Warning Letter_08102017_text.pdf",
      "url": "https://primis.phmsa.dot.gov/enforcement-documents/520176028W/520176028W_Warning%20Letter_08102017_text.pdf",
      "bytes": 87152,
      "category": "agency_document"
    }
  ],
  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "NOBLE MIDSTREAM SERVICES, LLC"
}
```
