CENTURION PIPELINE L.P. — Notice of Probable Violation

party submissionOfficial PDF420145025_Operator Petition for Reconsideration with Exhibits_04272017.pdf#

party submissionOfficial PDF420145025_Operator Petition For Review (United Sates Court of Appeals For the Fifth Circuit)_11162017.pdf#

420145025_Closure Letter_03202019_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED March 20, 2019 Jennifer Fontenot Chief Operating Officer Centurion Pipeline, LP 5 Greenway Plaza, Suite 1600 Houston, Texas 77046-7570 CPF 4-2014-5025 Dear Ms. Fontenot: On January 31, 2019, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Centurion Pipeline, LP a Consent Agreement and Order in the above-referenced case. This Order included a Compliance Order and Civil Penalty assessment. Based on our review of the documentation you provided and confirmation of payment of the civil penalty, 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, Mary L. McDaniel, P.E. Director, Southwest Pipeline and Hazardous Materials Safety Administration#

420145025_PHC Decision on Petition Reconsideration_10242017_text.pdf, page 1Official PDFOctober 24, 2017 Ms. Vicki Hollub President and Chief Executive Officer Occidental Petroleum Corporation 5 Greenway Plaza, Suite 110 Houston, TX 77046 Re: CPF No. 4-2014-5025 Dear Ms. Hollub: Enclosed please find the Decision on the Petition for Reconsideration filed by Centurion Pipeline, LP, a subsidiary of Occidental Petroleum Corporation, in the above-referenced case. For the reasons explained therein, the Decision affirms the violations in the Final Order and does not modify the civil penalty or compliance terms. When the civil penalty has been paid and the terms of the Compliance Order completed, as determined by the Director, Southwest Region, this enforcement action will be closed. This Decision constitutes the final administrative action in this proceeding. Service of this Decision is made pursuant to 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: Director, Southwest Region, Office of Pipeline Safety, PHMSA Mr. Scott Janoe, Esq., Baker Botts, LLP, 910 Louisiana St., Houston, TX 77002 Mr. Mike Morgan, General Manager – Operations, Centurion Pipeline, LP, 5 Greenway Plaza, Suite 110, Houston, TX 77046 CERTIFIED MAIL – RETURN RECEIPT REQUESTED#

420145025_PHC Decision on Petition Reconsideration_10242017_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 _________________________________________ In the Matter of ) Centurion Pipeline, LP, ) CPF No. 4-2014-5025 a subsidiary of Occidental Petroleum Corp., ) ) ) ) Petitioner. ) _________________________________________ ) DECISION ON PETITION FOR RECONSIDERATION Between January and June 2014, 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 investigation of an accident that occurred January 30, 2014, on a pipeline operated by Centurion Pipeline, LP (Centurion or Petitioner),1 near Snyder, Texas. Centurion operates approximately 2,500 miles of pipeline transporting crude oil in Texas, Oklahoma, and New Mexico.2 As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to Petitioner, by letter dated September 30, 2014, 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 Centurion had violated 49 C.F.R. §§ 195.404 and 195.442 and proposed a civil penalty of $165,600 for the alleged violations. The Notice also proposed ordering certain compliance measures to correct the alleged violations. Centurion responded to the Notice by letter dated October 30, 2014 (Response), contested the allegations, and requested a hearing. Centurion submitted additional materials on April 20, 2015. A hearing was held on April, 29, 2015, in Houston, Texas, with an attorney from the Office of Chief Counsel, PHMSA, presiding. After the hearing, Petitioner provided post-hearing statements for the record by letters dated June 26, 2015 (Closing), and August 14, 2015 (Supplemental Closing). Pursuant to § 190.209(b)(7), the Director submitted a written evaluation of Petitioner’s response material on July 9, 2015 (Recommendation). 1 Centurion is a subsidiary of Occidental Petroleum Corporation. See Centurion’s Petition for Reconsideration and Brief in Support, (April 27, 2017) (on file with PHMSA). 2 This information is reported by Centurion for 2015 pursuant to 49 C.F.R. § 195.49.#

420145025_PHC Decision on Petition Reconsideration_10242017_text.pdf, page 3CPF No. 4-2014-5025 Page 2 On March 31, 2017, pursuant to 49 C.F.R. § 190.213, PHMSA issued a Final Order in this proceeding, finding that Centurion committed violations of § 195.404(a) (Item 1) and § 195.442 (Item 2), as alleged in the Notice. The Final Order assessed a reduced civil penalty of $122,400, and ordered corrective action with respect to Item 1, as set forth in the Compliance Order. In accordance with 49 C.F.R. § 190.243, Centurion filed a timely Petition for Reconsideration (Petition) of the Final Order on April 27, 2017, seeking reconsideration of the violations, civil penalties, and Compliance Order. The filing of the petition automatically stayed payment of the assessed civil penalty pursuant to § 190.243(c), but did not stay the corrective actions required to be completed under the Compliance Order. Pursuant to 49 C.F.R. § 190.243, an operator may petition the Associate Administrator for reconsideration of a final order issued under § 190.213. Reconsideration does not constitute an appeal or an opportunity to seek a de novo review of the record. It is instead an opportunity for petitioners to request that errors in the final order be corrected or to present information that was not previously available, provided the petitioner submits a valid reason explaining why such information was not presented prior to issuance of the final order. PHMSA may grant or deny, in whole or in part, a petition for reconsideration without further proceedings, but may request additional information or comment if deemed appropriate. Under § 190.243(b), the petitioner must submit reasoning why any additional facts or arguments were not presented prior to issuance of the final order. Centurion did not submit additional facts or arguments in the Petition. Rather, Centurion continued to argue against PHMSA’s interpretations of 49 C.F.R. §§ 195.404(a) and 195.442(c)(5), repeating the same arguments and citing the same information contained in Petitioner’s previous submissions and discussed at the hearing. Centurion characterized its Petition as an attempt to clarify certain of its previous statements, which Petitioner asserted PHMSA “may have misinterpreted and/or misapplied.” 3 Background On November 12, 2013, in response to a one-call ticket submitted by an excavation contractor, Centurion located and temporarily marked two of its pipelines within the proposed excavation area. The two pipelines were Centurion’s parallel eight-inch and six-inch pipelines. Centurion’s maps indicated that the eight-inch pipeline was located south of Centurion’s parallel six-inch pipeline, but the actual location of the eight-inch pipeline at the site of the excavation was north of the six-inch pipeline within the same right-of-way. Centurion used existing maps and a Radio Detection RD8000 locator to locate the pipes and mark them. The six-inch pipeline was marked after the eight-inch line. The one-call ticket was renewed five times before excavation eventually started, each time prompting a site visit from Centurion, which verified the two pipelines were still marked. During excavation on January 30, 2014, two additional, unidentified pipes were discovered in the excavation area. Where Centurion had marked what it expected to be its eight-inch and six-inch pipelines, the excavator uncovered two six-inch pipes. Upon the discovery of a second six-inch 3 Petition, at 2.#

420145025_PHC Decision on Petition Reconsideration_10242017_text.pdf, page 4CPF No. 4-2014-5025 Page 3 pipeline, Centurion learned that its eight-inch pipeline had not been marked and attempted to locate and correctly mark the line. The excavator then partially exposed an eight-inch pipeline, which Centurion presumed was its own pipeline. This pipeline, however, was not Centurion’s line, but another eight-inch pipeline located directly above Centurion’s eight-inch line. Centurion’s eight-inch line still could not be seen at the excavation site. Believing Centurion’s eight-inch line had already been exposed, the excavation continued and Centurion’s eight-inch pipeline was struck and damaged. Analysis Item 1 in the Final Order found that Centurion violated 49 C.F.R. § 195.404(a), which states: §195.404 Maps and records. (a) Each operator shall maintain current maps and records of its pipeline systems that include at least the following information; (1) Location and identification of the following pipeline facilities; (i) Breakout tanks; (ii) Pump stations; (iii) Scraper and sphere facilities; (iv) Pipeline valves; (v) Facilities to which §195.402(c)(9) applies; (vi) Rights-of-way; and (vii) Safety devices to which §195.428 applies. (2) All crossings of public roads, railroads, rivers, buried utilities, and foreign pipelines. (3) The maximum operating pressure of each pipeline. (4) The diameter, grade, type and nominal wall thickness of all pipe. The Final Order determined that Petitioner violated 49 C.F.R. § 195.404(a) by failing to maintain current maps of its pipeline systems. Specifically, PHMSA found that Centurion did not maintain a current map of its eight-inch Snyder-to-Post crude pipeline. On January 30, 2014, Centurion’s eight-inch pipeline suffered third-party damage during excavation. Maps used by Centurion to temporarily mark the eight-inch pipeline prior to excavation incorrectly showed the pipeline was south of a parallel six-inch pipeline also operated by Centurion. The correct location of the eight-inch pipeline was discovered to be north of the six-inch line. In the Petition, Centurion argued the finding of violation in Item 1 should be reversed for several reasons. The specific assertions made by Petitioner were that: (1) Centurion’s maps complied with regulatory and industry standards; (2) Centurion’s marking of the other eight-inch pipeline immediately above Centurion’s eight-inch pipeline rendered the maps accurate; and (3) Centurion’s maps were not required to accurately indicate the position of Centurion’s eight-inch pipeline relative to other pipelines in the area. These arguments were previously raised in response to the Notice, at the hearing, and in subsequent submissions and were rejected in the Final Order. Finding no reason to modify the findings in the Final Order, PHMSA affirms the violation of § 195.404(a).#

420145025_PHC Decision on Petition Reconsideration_10242017_text.pdf, page 5CPF No. 4-2014-5025 Page 4 Item 2 in the Final Order found that Centurion violated 49 C.F.R. § 195.442(c)(5), which states: § 195.442 Damage prevention program. (a) . . . . (c) The damage prevention program required by paragraph (a) of this section must, at a minimum: … (5) Provide for temporary marking of buried pipelines in the area of excavation activity before, as far as practical, the activity begins. The Final Order determined that Petitioner violated 49 C.F.R. § 195.442(c)(5) by failing to provide correct temporary markings in the area of the excavation activity before the activity began. Specifically, PHMSA found that Centurion failed to provide accurate temporary markings of its eight-inch pipeline when it twice mis-marked the pipe’s location. Petitioner attempted to locate and mark its eight-inch pipeline on November 12, 2013, and again on January 30, 2014 (the day of the accident). Each time, Petitioner failed to accurately mark its eight-inch pipeline, which eventually resulted in damage to the pipeline by a third-party contractor using excavation equipment. In the Petition, Centurion argued the finding of violation in Item 2 should be reversed for several reasons. The specific assertions made by Petitioner were that: (1) Centurion properly marked its pipelines in compliance with regulatory and industry standards; (2) but for the existence of the other eight-inch pipeline immediately above Centurion’s eight-inch pipeline, no damage would have resulted to Centurion’s line; (3) the finding of violation in Item 2 imposed a strict liability standard on Petitioner; and (4) but for the excavator’s failure to comply with Texas law concerning the area of excavation, no damage would have resulted to Centurion’s line. Arguments (1), (2), and (4) were previously raised in response to the Notice, at the hearing, and in subsequent submissions and were rejected in the Final Order. With regard to argument (3), Petitioner did not articulate how the finding of violation in Item 2 of the Final Order imposed a strict liability standard on Centurion. Presumably, Petitioner intended to assert that Item 2 was premised entirely on the fact that excavation activity resulted in damage to Centurion’s eight- inch line. This argument is without merit; the finding of violation documented in the Final Order demonstrated that Centurion did not mark its own pipeline, but, rather marked an unidentified pipeline operated by another company. Finding no reason to modify the findings in the Final Order, PHMSA affirms the violation of § 195.442(c)(5). Conclusion Based on a review of the record and the information provided in the Petition, I hereby deny the Petition and affirm the Final Order without modification, for the reasons set forth above. Payment of the $122,400 civil penalty assessed in the Final Order is now due and must be made within 20 days of service of this Decision. The payment instructions were set forth in detail in the Final Order. Failure to pay the $122,400 civil penalty will result in accrual of interest at the#

420145025_PHC Decision on Petition Reconsideration_10242017_text.pdf, page 6CPF No. 4-2014-5025 Page 5 current annual rate 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 United States District Court. All other terms of the Final Order remain in effect, including terms of the Compliance Order, which were required to be completed by Centurion and submitted to the Director, Southwest Region no later than 90 days from receipt of the Final Order, or no later than July 5, 2017. This Decision constitutes final agency action taken by PHMSA in the enforcement proceeding. The terms and conditions of this Decision are effective upon service in accordance with 49 C.F.R. § 190.5. October 24, 2017 _____________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

420145025_Consent Order and Agreement_01312019_text.pdf, page 1Official PDFCPF No. 4-2014-5025 Page 1 U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, DC 20590 In the Matter of ) Centurion Pipeline, LP, ) CPF No. 4-2014-5025 a subsidiary of Occidental Petroleum Corp., ) Respondent. ) ) ) ) ) CONSENT AGREEMENT AND ORDER The U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA), and Centurion Pipeline, LP (Centurion or Respondent) have engaged in settlement discussions regarding the resolution of the enforcement action listed above and the Petition for Review filed by Centurion in the U.S. Court of Appeals for the Fifth Circuit, Case No. 17-60775. Having concluded those discussions, PHMSA and Centurion (collectively, Parties) agree that a settlement of this matter is in the best interests of the Parties and the public and will avoid further administrative proceedings or litigation. The Parties further agree that the entry of this Consent Agreement and Order (Agreement) is the most appropriate means of accomplishing that objective. I. Procedural History On September 30, 2014, PHMSA issued to Centurion a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice). The Notice alleged that Centurion had committed violations of 49 C.F.R. §§ 195.404 and 195.442 and proposed an administrative civil penalty of $165,600 for the alleged violations. The Notice also proposed ordering certain compliance measures to correct the alleged violations. Centurion responded to the Notice by letter dated October 30, 2014, contested the allegations, and requested a hearing. A hearing was held on April 29, 2015, in Houston, Texas, with an attorney from the Office of Chief Counsel, PHMSA, presiding. After the hearing, Centurion provided post-hearing statements for the record on June 26, 2015, and August 14, 2015. Pursuant to § 190.209(b)(7), the Director of the Southwest Region, Office of Pipeline Safety, PHMSA, submitted a written evaluation of Centurion’s response material on July 9, 2015.#

420145025_Consent Order and Agreement_01312019_text.pdf, page 2CPF No. 4-2014-5025 Page 2 On March 31, 2017, pursuant to 49 C.F.R. § 190.213, PHMSA issued a Final Order in this proceeding, finding that Centurion committed violations of § 195.404(a) (Item 1) and § 195.442 (Item 2), as alleged in the Notice. The Final Order assessed a reduced civil penalty of $122,400, and ordered corrective action with respect to Item 1, as set forth in the Compliance Order. In accordance with 49 C.F.R. § 190.243, Centurion filed a timely Petition for Reconsideration of the Final Order on April 27, 2017, seeking reconsideration of the violations, civil penalties, and Compliance Order. The filing automatically stayed payment of the assessed civil penalty pursuant to § 190.243(c), but did not stay the corrective actions required to be completed under the Compliance Order. On October 24, 2017, PHMSA issued a Decision on Petition for Reconsideration, denying the Petition and affirming the Final Order without modification. On November 17, 2017, Centurion filed a petition for review in the United States Court of Appeals for the Fifth Circuit challenging the Associate Administrator's findings of violation, in a case styled Centurion Pipeline, L.P. v. TRAN, et al., Agency No. 4-2014-5025, Case No. 17-60775 (Petition). Under the terms and conditions set forth in this Agreement, the Parties have now resolved the issues underlying the Notice, Final Order, and Petition, and Centurion will dismiss its Petition as provided in Paragraph 13 of this Agreement. II. General Provisions. 1. Respondent acknowledges that its pipeline system is subject to the jurisdiction of the federal Pipeline Safety Laws, 49 U.S.C. §§ 60101, et seq., and the regulations and administrative orders issued thereunder. As used in this Agreement, the term “pipeline system” shall be defined as in 49 C.F.R. Part 195. Respondent acknowledges that it received proper notice of PHMSA’s action in this proceeding and that the Notice states claims upon which relief may be granted pursuant to 49 U.S.C. §§ 60101, et seq., and the regulations and orders issued thereunder. 2. Respondent consents to the issuance of this Agreement and hereby waives any further procedural requirements with respect to its issuance. Respondent waives all rights to contest the adequacy of notice or the validity of this Agreement, including all rights to administrative or judicial hearings, reviews, or appeals. 3. This Agreement constitutes the final, complete, and exclusive agreement and understanding between the Parties with respect to the settlement embodied in this Agreement, and the Parties acknowledge that there are no representations, agreements, or understandings relating to the settlement other than those expressly contained in this Agreement. 4. Nothing in this Agreement affects or relieves Respondent of its responsibility to comply with all applicable requirements of the federal Pipeline Safety Laws, 49 U.S.C. §§ 60101, et seq., and the regulations and orders issued thereunder. Nothing in this Agreement alters PHMSA’s right of access, entry, inspection, and information-gathering or its authority to bring any enforcement action against Respondent pursuant to the federal Pipeline Safety Laws, the regulations and orders issued thereunder.#

420145025_Consent Order and Agreement_01312019_text.pdf, page 3CPF No. 4-2014-5025 Page 3 5. This Agreement does not waive or modify any federal, state, or local laws or regulations that are applicable to Respondent or its pipeline system. This Agreement is not a permit, or a modification of any permit, under any federal, state, or local laws or regulations. Respondent remains responsible for achieving and maintaining compliance with all applicable federal, state, and local laws, regulations and permits. 6. This Agreement does not create rights in, or grant any cause of action to, any third party not a party to this Agreement. 7. This Agreement shall apply to and be binding on PHMSA and Centurion, its officers, directors, employees, successors and assigns, including, but not limited to, any subsequent purchaser of the at issue pipelines. III. Amendments to Final Order and Related Provisions 8. By entry of this Agreement, PHMSA amends the provisions in the Final Order as they relate to Item 1, the alleged violation of 49 C.F.R. § 195.404(a). PHMSA amends Item 1 to a Warning Item pursuant to 49 C.F.R. § 190.205. PHMSA’s determination that Centurion violated 49 C.F.R. § 195.442(c)(5) (Item 2) is not amended in any way, and remains in place. PHMSA may choose to consider Item 1 and Item 2 to be prior findings of violation in future PHMSA enforcement actions brought against Centurion. 9. By entry of this Agreement, PHMSA amends the Final Order to assess a total civil penalty of Ninety-Two Thousand Dollars ($92,000.00). 10. Centurion will pay the civil penalty amount in Paragraph 10 within 30 calendar days of the Effective Date of this Agreement. Payment shall be made by wire transfer through the Federal Reserve Communications System (Fedwire), to the account of the U.S. Treasury, as outlined in the Final Order. 11. Centurion stipulates that the facts as alleged in the Notice are true and correct, but denies that it violated the Federal pipeline safety regulations. 12. the Compliance Order. PHMSA finds that Centurion has completed all compliance measures contained in IV. Dismissal of Petition for Review 13. Within three (3) business days after the Effective Date of this Agreement, Centurion shall file with the U.S. Court of Appeals for the Fifth Circuit a motion to dismiss the Petition pursuant to Rule 42(b) of the Federal Rules of Appellate Procedure, specifying that the Parties will bear their own costs and fees.#

420145025_Consent Order and Agreement_01312019_text.pdf, page 4CPF No. 4-2014-5025 Page 4 V. Effective Date 14. The “Effective Date,” as used herein, is the date on which this Agreement is signed by both Respondent and PHMSA. The Parties hereby agree to all conditions and terms of this Agreement: For PHMSA: For Centurion Pipeline, LP: _______________________________ _________________________________ Alan K. Mayberry _________ Associate Administrator for Pipeline Safety, PHMSA Centurion Pipeline, LP#

420145025_NOPV PCP PCO_09302014_text.pdf, page 1Official PDFNOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER CERTIFIED MAIL - RETURN RECEIPT REQUESTED September 30, 2014 Bill Boyer President Centurion Pipeline, L.P. 5 Greenway Plaza, Suite 110 Houston, TX 77046 CPF 4-2014-5025 Dear Mr. Boyer: On January 30, 2014, Centurion Pipeline Company, L.P. (Centurion) experienced an excavated related accident on its Snyder-to-Post 8-inch line near Snyder, TX. As a result of this accident, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code conducted an accident investigation and performed an inspection of your related Damage Prevention practices. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation(s) are: 1. §195.404 Maps and Records. (a) Each operator shall maintain current maps and records of its pipeline systems that include at least the following information; (1) Location and identification of the following pipeline facilities; (i) Breakout tanks; (ii) Pump stations;#

420145025_NOPV PCP PCO_09302014_text.pdf, page 2(iii) Scraper and sphere facilities; (iv) Pipeline valves; (v) Facilities to which §195.402(c)(9) applies; (vi) Rights-of-way; and (vii) Safety devices to which §195.428 applies. (2) All crossings of public roads, railroads, rivers, buried utilities, and foreign pipelines. (3) The maximum operating pressure of each pipeline. (4) The diameter, grade, type and nominal wall thickness of all pipe. Centurion did not maintain a current map of the 8-inch Snyder-to-Post crude pipeline system at milepost 3.63, as required by §195.404. On January 30, 2014, Centurion’s incorrectly marked pipeline, ¼ miles Northwest of the City of Snyder, (Scurry County) Texas, was damaged while excavation was being performed in the area by an excavator. Maps used to temporarily mark the 8-inch pipeline prior to excavation, indicated the pipeline was south of a parallel 6-inch pipeline, also operated by Centurion. The accurate location of the 8-inch pipeline at milepost 3.63 was discovered to be north of the 6-inch within the same right-of-way. ADB-02-03 issued by DOT advised owners and operators to review information and mapping systems for accurate and useable information. The existing mapping data for the 8-inch pipeline was not confirmed to be accurate by Centurion. 2. §195.442 Damage Prevention Program. (c) The damage prevention program required by paragraph (a) of this section must, at a minimum: (5) Provide for temporary marking of buried pipelines in the area of excavation activity before, as far as practical, the activity begins. Centurion failed to provide accurate temporary markings of the Snyder-to-Post 8-inch pipeline at MP 3.63 in Scurry County, Texas. Prior to the start of excavation, the Snyder-to-Post line was temporarily marked by Centurion personnel in response to a one-call request received in November 2013. On January 30, 2014, the pipeline was punctured with excavation equipment by a third-party contractor, causing an estimated 475 barrels to be released to the environment. During the investigation, it was discovered the pipeline was twice mismarked by personnel. The first instance occurred during the initial response to the one-call request on November 12, 2013. The initial marking was performed with the assistance of electronic maps and locating equipment (Radio Detection RD8000 locator) available to Centurion personnel. The second occurrence took place during excavation activities on January 30, 2014 after field personnel recognized the erroneous markings, and attempted to accurately mark the lines by exposing the pipelines. An unaccounted for 8-inch pipeline discovered during excavation was incorrectly marked as belonging to Centurion. As the third party contractor was excavating this line, the unmarked Snyder-to-Post 8-inch was damaged. 2#

420145025_NOPV PCP PCO_09302014_text.pdf, page 3Proposed Civil Penalty Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations. The Compliance Officer has reviewed the circumstances and supporting documentation involved in the above probable violation(s) and has recommended that you be preliminarily assessed a civil penalty of $165,600 as follows: Item number PENALTY 1 $ 21,600 2 $144,000 Proposed Compliance Order With respect to item 1 pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Centurion Pipeline, L.P. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Response to this Notice Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Compliance 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). 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. In your correspondence on this matter, please refer to CPF 4-2014-5025 and for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, R. M. Seeley Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Compliance Proceedings 3#

420145025_NOPV PCP PCO_09302014_text.pdf, page 4PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Centurion Pipeline, L.P. (Centurion) a Compliance Order incorporating the following remedial requirements to ensure the compliance of Centurion with the pipeline safety regulations: 1. 2. 3. In regard to Item 1 of the Notice pertaining to maps of the Snyder-to-Post pipeline, Centurion must revise/update information and mapping systems for the Snyder-to-Post 8- inch pipeline from milepost 0 through 5 to accurately reflect the location and identification of the pipeline facilities. Provide PHMSA with documentation that verifies completion of Item 1 within 90 days following the receipt of the Final Order. It is requested (not mandated) that Centurion maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to R. M. Seeley, Director, Southwest, 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. 4#

420145025_Final Order_03312017_text.pdf, page 1Official PDFMarch 31, 2017 Mr. Mike Morgan General Manager - Operations Centurion Pipeline L.P. 5 Greenway Plaza, Suite 110 Houston, TX 77046 Re: CPF No. 4-2014-5025 Dear Mr. Morgan: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation, assesses a reduced civil penalty of $122,400, and specifies corrective action that must be completed. The penalty payment terms are set forth in the Final Order. When the civil penalty has been paid and the terms of the compliance order completed, as determined by the Director, Southwest Region, this enforcement action will be closed. Service of the Final Order is made pursuant to 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: Mr. R. M. Seeley, Director, Southwest Region, PHMSA, OPS Mr. Ahren Tryon, Tryon Law Firm 4148 Hockaday Drive, Dallas, Texas 75229 CERTIFIED MAIL – RETURN RECEIPT REQUESTED#

420145025_Final Order_03312017_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ ) In the Matter of ) ) Centurion Pipeline, LP, ) a subsidiary of Occidental ) Petroleum Corp., ) CPF No. 4-2014-5025 ) Respondent. ) ____________________________________) FINAL ORDER Between January and June 2014, 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 investigation of an accident that occurred January 30, 2014, on a pipeline operated by Centurion Pipeline, LP (Centurion or Respondent), in Houston, Texas. Centurion operates approximately 2,500 miles of pipeline transporting crude oil in Texas, Oklahoma and New Mexico.1 As a result of the inspection, the Director, Southwest Region, OPS (Director) issued to Respondent, by letter dated September 30, 2014, 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 Centurion had violated 49 C.F.R. §§ 195.404 and 195.442 and proposed a civil penalty of $165,600 for the alleged violations. The Notice also proposed ordering certain compliance measures to correct the alleged violations. Centurion responded to the Notice by letter dated October 30, 2014 (Response), contested the allegations, and requested a hearing. Centurion submitted additional materials on April 20, 2015. A hearing was held on April, 29, 2015, in Houston, Texas, with an attorney from the Office of Chief Counsel, PHMSA, presiding. After the hearing, Respondent provided post- hearing statements for the record by letters dated June 26, 2015 (Closing) and August 14, 2015 (Supplemental Closing). Pursuant to § 190.209(b)(7), the Director submitted a written evaluation of Respondent’s response material on July 9, 2015 (Recommendation). 1 This information is reported by Centurion for 2015 pursuant to 49 C.F.R. § 195.49.#

420145025_Final Order_03312017_text.pdf, page 3FINDINGS OF VIOLATION The Notice alleged that Respondent violated 49 C.F.R. Part 195, as follows: Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.404(a), which states in relevant part: §195.404 Maps and records. (a) Each operator shall maintain current maps and records of its pipeline systems that include at least the following information; (1) Location and identification of the following pipeline facilities; (i) Breakout tanks; (ii) Pump stations; (iii) Scraper and sphere facilities; (iv) Pipeline valves; (v) Facilities to which §195.402(c)(9) applies; (vi) Rights-of-way; and (vii) Safety devices to which §195.428 applies. (2) All crossings of public roads, railroads, rivers, buried utilities, and foreign pipelines. (3) The maximum operating pressure of each pipeline. (4) The diameter, grade, type and nominal wall thickness of all pipe. The Notice alleged that Respondent violated 49 C.F.R. § 195.404(a) by failing to maintain current maps of its pipeline systems. Specifically, the Notice alleged that Centurion did not maintain a current map of the eight-inch Snyder-to-Post crude pipeline. On January 30, 2014, Centurion’s pipeline suffered third-party damage during excavation. Maps used by Centurion to temporarily mark the eight-inch pipeline prior to excavation incorrectly showed the pipeline was south of a parallel six-inch pipeline also operated by Centurion. The correct location of the eight-inch pipeline was discovered to be north of the six-inch line. Respondent argued that the alleged violation should be withdrawn because OPS did not apply a proper standard for determining compliance with § 195.404. In particular, Respondent noted that the regulation requires maps to be “current,” but the Notice alleged Respondent’s maps were not “accurate.” Respondent argued that its maps were indeed current. For example, when Respondent acquired the pipelines in 2007, the Company used in-line inspection data to create the maps and also purchased geospatial data. The pipelines then underwent “mapping data accuracy verification via an internal inspection tool equipped with an inertial mapping unit.”2 Centurion also planned to use information from the excavation on January 30, 2014, to update its system maps. Respondent also contended that its maps were far more accurate than the standard for accuracy that applies to the submission of location information in the National Pipeline Mapping 2 Closing, at 10.#

420145025_Final Order_03312017_text.pdf, page 4System (NPMS). The NPMS, Respondent argued, requires accuracy within 500 feet, while Respondent’s maps were only off by eight feet. Respondent argued that it should not be penalized for using “best practices” to maintain its system maps.3 Respondent also asserted that it was under no obligation to map the Company’s six-inch line that was near the damaged eight- inch line because the six-inch line was not subject to the pipeline safety regulations in Part 195. At the Hearing, the Director explained that Respondent’s map depicted the eight-inch pipeline in the wrong place. Specifically, the map incorrectly depicted the eight-inch pipeline in relation to the six-inch unregulated pipeline. This is what the Notice meant by alleging the maps were not “accurate.” The Director also noted that an Advisory Bulletin previously issued by PHMSA advises operators that documents, including maps, used in the performance of operations required under Part 195 should contain clear and useable information. Applicable Safety Standards Section 195.404(a) requires a pipeline operator to maintain “current maps and records” of its pipeline system. Maps include those depicting the location of an operator’s pipeline facility, including the location of pipe, valves, safety devices, crossings of roads, utilities, and foreign pipelines, and other information such as maximum operating pressure. As PHMSA has previously stated, “Inherent in an operator’s obligation under § 195.404(a) to maintain ‘current maps and records’ is the need for such records to be complete and accurate.”4 Under this regulation, an operator is required to maintain not just current maps, but accurate maps. In 2002, PHMSA issued a safety bulletin titled “Pipeline Safety: Gas and Hazardous Liquid Pipeline Mapping.”5 The Advisory Bulletin advises each pipeline operator to review information and mapping systems “to ensure that the operator has clear, accurate, and useable information on the location and characteristics of all pipes, valves, regulators, and other pipeline elements for use in emergency response, pipe location and marking, and pre-construction planning.”6 Findings On January 30, 2014, Respondent’s eight-inch pipeline was damaged during excavation by a third party. Respondent had used its own maps to temporarily mark the eight-inch pipeline prior to the excavation. The maps indicated the pipeline was located south of the Company’s parallel six-inch pipeline, but the actual location of the eight-inch pipeline at the site of the excavation 3 Supplemental Closing, at 12. 4 Plantation Pipe Line Co., CPF No. 1-2005-5017, at 5, 2009 WL 1211364 (Mar. 27, 2009). 5 Pipeline Safety: Gas and Hazardous Liquid Pipeline Mapping, 67 Fed. Reg. 40,768 (June 13, 2002) (Advisory Bulletin). 6 Id. Because the plain language of the regulation and subsequent guidance issued by PHMSA notified Respondent of the requirement to maintain current maps in accordance with § 195.404, Respondent’s contention that it did not have notice of the requirement is rejected.#

420145025_Final Order_03312017_text.pdf, page 5was north of the six-inch pipeline within the same right-of-way. This evidence demonstrates Respondent’s maps were not current or accurate. While Respondent argued its maps were only off by eight feet, § 195.404(a) does not establish a prescriptive standard of accuracy measured in feet. The regulation establishes a performance standard. PHMSA has explained the performance standard means, at a minimum, that the information must be accurate enough to be useable for its intended purpose. On the date of the excavation, Respondent’s maps were used to mark a pipeline for the purpose of avoiding excavation damage, but the maps were inaccurate, which led to inaccurate markings and eventually damage to the pipeline. Respondent’s assertion that an accuracy standard of 500 feet should apply under § 195.404 is rejected. The 500-foot standard cited by Respondent is for the submission of data to the NPMS and is not a regulatory standard under § 195.404. There is no support in Part 195 for Respondent’s assertion that the NPMS data submission standard applies to the maps and records required to be maintained under § 195.404. Respondent also asserted that the Company was not required to accurately reflect the relative location of the unregulated six-inch pipeline. This assertion is also rejected. Section 195.404 required Respondent to have maps and records that showed not only proximity of the regulated eight-inch pipeline to other pipelines, but also nearby utilities and foreign pipelines. Since the maps must include other pipelines and non-pipeline utilities, the maps were required to have an accurate depiction of Respondent’s nearby six-inch pipeline. Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R. § 195.404(a) by failing to maintain a map that depicted the location of its eight-inch pipeline relative to its six-inch line. Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.442, which states in relevant part: § 195.442 Damage prevention program. (a) . . . . (c) The damage prevention program required by paragraph (a) of this section must, at a minimum: (5) Provide for temporary marking of buried pipelines in the area of excavation activity before, as far as practical, the activity begins. The Notice alleged that Respondent violated 49 C.F.R. § 195.442 by failing to provide correct temporary markings in the area of the excavation activity before the activity began. Specifically, the Notice alleged that Centurion failed to provide accurate temporary markings of the eight-inch pipeline when it twice mismarked the pipe’s location. Respondent attempted to locate and mark the eight-inch pipeline on November 12, 2013, and again on January 30, 2014 (the day of the accident). Each time, Respondent failed to accurately mark the eight-inch pipeline, which eventually resulted in damage to the pipeline by a third-party contractor using excavation equipment.#

420145025_Final Order_03312017_text.pdf, page 6On November 12, 2013, in response to a one-call ticket submitted by the excavation contractor, Respondent located and temporarily marked two of its pipelines within the proposed excavation area. The two pipelines were the eight-inch pipeline and the six-inch pipeline. Respondent used existing maps and a Radio Detection RD8000 locator to locate the pipes and mark them. The six-inch pipeline was marked after the eight-inch line. The one-call ticket was renewed five times before excavation eventually started, each time prompting a site visit from Centurion, which verified the two pipelines were still marked.7 During excavation on January 30, 2014, two additional, unidentified pipes were discovered in the excavation area. Where Respondent had marked what it expected to be its eight-inch and six- inch pipelines, the excavator uncovered two six-inch pipes. Upon the discovery of a second six- inch pipeline, Respondent believed its own eight-inch pipeline had been mismarked and attempted to locate and correctly mark the line.8 The excavator then partially exposed an eight- inch pipeline, which Centurion presumed was its own pipeline. This pipeline, however, was not Respondent’s line, but another eight-inch pipeline located directly above Respondent’s line. Centurion’s line still could not be seen at the excavation site. Believing Respondent’s eight-inch line had already been exposed, the excavation continued and Respondent’s pipeline was struck and damaged. At the hearing and in its written submission, Respondent admitted that it had mismarked its eight-inch pipeline.9 Respondent disputed, however, that the line was mismarked again during the excavation. The Company argued that because the pipeline was directly beneath the unknown eight-inch pipe that had been exposed, its markings should be considered accurate, regardless of whether it thought the unknown pipe was its own pipeline.10 Respondent contended further that its temporary markings were within the “area of excavation activity” as required by § 195.442(c)(5) because the marks were directly over the point of impact, and the paint line was in the area the excavator was working. Respondent also argued the Texas Administrative Code defines a “tolerance zone” for excavations that would be roughly 44 inches in this instance.11 In conclusion, Respondent argued that Centurion’s marking was exactly over the location where the pipeline was struck and damaged.12 7 Pipeline Safety Violation Report (Violation Report), (Sep. 30, 2014) (on file with PHMSA), at 11-12. 8 Violation Report, Ex. C, at 6 (Internal Review Meeting: Third Party Strike on Centurion’s Snyder to Post 8in Crude Oil Pipeline) (Mar. 5, 2014). 9 Tr., at 169-70; Violation Report, Ex. C, at 2-3. 10 Tr., at 172, 180-81; Closing, at fn 12; Supplemental Closing, at 10. 11 Tr., at 179; Closing, at 21 (citing Texas Administrative Code Title 16, Section 18.10). 12 Supplemental Closing, at 7; Closing, at 20-12.#

420145025_Final Order_03312017_text.pdf, page 7Applicable Safety Standards Section 195.442(c)(5) requires a pipeline operator to have a written program to prevent damage to its buried pipelines from excavation activities. The damage prevention program must include, at a minimum, a means to receive notification of planned excavation activities, to notify the prospective excavator of the presence of its pipelines in the area of planned excavation, and to “provide for temporary marking of buried pipelines in the area of excavation activity” before the activity begins. Findings On November 12, 2013, Centurion responded to a notification of planned excavation by attempting to provide temporary marking of its buried eight-inch pipeline in the area of the planned excavation. After the excavation activity began, it was determined that the marking was not accurate because the marking revealed a six-inch pipeline. After the six-inch pipeline was exposed, Respondent attempted to identify and temporarily mark the eight-inch pipeline again, but that marking too was inaccurate, as the marking turned out to be another operator’s eight- inch line, which was previously unidentified. As the excavation continued, Respondent’s eight- inch pipeline was damaged because its true position was never identified during temporary marking, as required by § 195.442(c)(5). While Respondent argued that it had complied with the regulation because its pipeline was directly beneath the unidentified eight-inch line that it had marked and all the markings were in the “area of excavation,” I reject this argument. Respondent did not mark its own pipeline, but rather marked an unidentified pipeline operated by another company. Thereafter, excavation continued until Centurion’s pipeline was damaged. Respondent’s markings therefore did not comply with the regulatory requirement. Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R. § 195.442 by failing to provide correct temporary markings on its buried pipeline in the area of excavation activity before the activity began. These findings of violation will be considered prior offenses 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. 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; and any effect that the penalty may have on its ability to continue#

420145025_Final Order_03312017_text.pdf, page 8doing business; and the good faith of Respondent in attempting to comply with the pipeline safety regulations. In addition, I may consider the economic benefit gained from the violation without any reduction because of subsequent damages, and such other matters as justice may require. The Notice proposed a total civil penalty of $165,600 for the violations cited above. Item 1: The Notice proposed a civil penalty of $21,600 for Respondent’s violation of 49 C.F.R. § 195.404, for failing to maintain current maps of its pipeline systems. With respect to the nature and circumstances of the violation, OPS alleged this was a records violation that Respondent discovered and self-reported, which served to mitigate the penalty as reflected in the proposed amount.13 With respect to gravity, OPS alleged the violation significantly compromised pipeline safety. OPS did not propose a credit under either the culpability or good faith factors because Respondent failed to take appropriate action to comply with the regulation. Respondent argued the penalty should be reduced because the proposed amount did not take into consideration the accuracy of Respondent’s maps, which were only off by eight feet, and that the six-inch pipeline was unregulated. I have already rejected these assertions above under the Finding of Violation section. Therefore, I find they are not a basis to reduce the penalty. Respondent also argued the penalty should be reduced because Centurion had taken measures to verify the accuracy of its maps prior to the excavation damage, and in fact, the third-party operator of other pipelines in the area of excavation bears responsibility for the damage. These arguments are also rejected as I find Respondent is responsible for the accuracy of its own pipeline maps, regardless of when or from whom it acquired the pipelines. Respondent had owned the pipelines for approximately seven years prior to the incident, and its efforts to verify the accuracy were insufficient to warrant a penalty reduction in this case. Finally, contrary to Respondent’s assertion, the fact that it self-reported the violation does not require further reduction of the penalty under “good faith.” When considering an operator’s good faith in attempting to comply, PHMSA looks at the attempt to comply with prior to the occurrence of the violation.14 Respondent’s self-reporting of the violation has no bearing on whether or not the Company had made a good-faith effort to have current maps when the violation occurred. As indicated above, however, the self-report did factor into the proposed penalty under the circumstances factor. Having reviewed the civil penalty assessment factors, I find the evidence supports assessment of the proposed penalty. Accordingly, Respondent is assessed a civil penalty of $21,600 for the violation of 49 C.F.R. § 195.404. 13 Violation Report, at 7. 14 Enterprise Products Operating, LLC, CPF 4-2013-5011, 2016 WL 1104436, at 9 (Feb. 4, 2016).#

420145025_Final Order_03312017_text.pdf, page 9Item 2: The Notice proposed a civil penalty of $144,000 for Respondent’s violation of 49 C.F.R. § 195.442(c)(5), for failing to provide correct temporary markings on a buried pipeline in the area of excavation activity before the activity began. With respect to the nature and circumstances of the violation, OPS alleged the violation concerned a failure to perform a required activity and it was discovered by PHMSA. With respect to gravity, OPS alleged the violation was a causal factor in the accident, which is the most severe gravity rating. OPS offered mitigating information reflected in the proposed penalty to account for good faith by Respondent and “significant steps” towards compliance, even though compliance was not achieved.15 Respondent argued the penalty should be reduced because the Violation Report inaccurately stated the violation lasted 79 days, which did not account for the fact that the excavation ticket was reissued several times. At the hearing, OPS explained that duration information was calculated from the date of the first location ticket issuance, but that the civil penalty was not adjusted beyond a single-day violation. Since the duration of the violation did not impact the proposed penalty amount, Respondent’s argument is not grounds to reduce the penalty. Respondent also stated that the penalty should be reduced because Respondent’s conduct was not “a causal factor in an accident/incident.”16 Respondent claimed that it had “marked directly over the location of the eight-inch Snyder-to-Post pipeline in the area of excavation activity which was directly over the point of the strike.” Respondent argued that it “would defy logic for PHMSA to assert that the pipeline was struck because Centurion failed to place a mark where the excavation activity was taking place.”17 I disagree. While other factors contributed to the accident, Respondent’s failure to correctly mark its Snyder-to-Post-eight-inch pipe was a causal factor in the accident. In particular, Respondent mistakenly marked an unidentified pipeline, not its own pipeline. After the unidentified pipeline was unearthed, the excavator continued digging while Respondent believed its pipeline had already been safely exposed. Respondent’s pipeline had not actually been marked and was struck by the excavator as work continued. Therefore, I do not find Respondent’s assertion warrants reducing the penalty. Finally, Centurion argued that the penalty should be reduced because the third-party operator of the other pipelines in the area of excavation bears responsibility for the damage. While an operator will generally be considered culpable for any failure to comply with a regulation absent some justification for the failure,18 in this case I find there were certain events outside of Respondent’s control that contributed to the violation. Specifically, a third-party operator of pipelines in the area of the excavation failed to comply with applicable safety requirements by responding to the one-call ticket location requests and by marking its pipelines. The failure of 15 Violation Report, at 17. 16 Closing, at 27; Supplemental Closing, at 13; Violation Report, at 16. 17 Closing, at 27. 18 Enterprise Products Operating, LLC, CPF 4-2013-5011, 2016 WL 1104436, at 9 (Feb. 4, 2016).#

420145025_Final Order_03312017_text.pdf, page 10that operator to mark its own pipelines in the area of excavation increased the likelihood of confusion between Respondent’s pipelines and the unknown and unidentified third-party pipelines during the excavation. Respondent ultimately bears responsibility for accurately marking its own lines, but I find the civil penalty should be reduced to take into consideration these facts concerning culpability. Accordingly, having reviewed the civil penalty assessment factors, I find the evidence supports assessing a reduced civil penalty of $100,800 for the violation of 49 C.F.R. § 195.442. In summary, having reviewed the record and considered the assessment criteria for each of the Items cited above, I assess Respondent a total civil penalty of $122,400. 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 $122,400 civil penalty will result in accrual of interest at the current annual rate 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 the violations cited above in Item 1. Under 49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids by pipeline or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. Centurion asserted that it complied with the terms of the proposed compliance order because all relevant information gained from its review of the incident has been integrated into the maps and records of the eight-inch pipeline. At the hearing, Respondent presented an updated map that reflected the accurate position of the pipelines relative to each other in the area of the excavation damage. I find these actions did not adequately address the terms of the proposed compliance order, which proposed actions to ensure the map is accurate from milepost 0 through 5. Accordingly, pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its operations:#

420145025_Final Order_03312017_text.pdf, page 111. With respect to the violation of § 195.404(a) (Item 1), Centurion must revise and update information and mapping systems for the Snyder-to-Post eight-inch pipeline from milepost 0 through 5 to accurately reflect the location and identification of the pipeline facilities. Centurion must submit documentation that verifies completion of this compliance order within 90 days following receipt of the Final Order. Documentation must be submitted to the Director, Southwest Region. 2. It is requested that Centurion maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total cost to the Director. 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. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent, demonstrating good cause for an extension. Failure to comply with this Order may result in administrative assessment of civil penalties not to exceed the amounts set forth in 49 C.F.R. § 190.223 (currently $205,638 for each violation for each day the violation continues) or in referral to the Attorney General for appropriate relief in a district court of the United States. Under 49 C.F.R. § 190.243, Respondent may submit a petition for reconsideration of this Final Order to the Associate Administrator for Pipeline Safety, PHMSA, 1200 New Jersey Avenue SE, East Building, 2nd Floor, Washington, D.C. 20590, no later than 20 days after receipt of the Final Order by Respondent. Any petition submitted must contain a 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 corrective action, remain in effect unless the Associate Administrator, upon request, grants a stay. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. March 31, 2017 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#