DCP MIDSTREAM — Notice of Probable Violation

party submissionOfficial PDF420175032_Operator Response to Notice_10272017.pdf#

420175032_Final Order__04122018_text.pdf, page 1Official PDFApril 12, 2018 Mr. Wouter van Kempen Chairman and CEO DCP Midstream, LP 370 17th Street, Suite 2500 Denver, CO 80202 Re: CPF No. 4-2017-5032 Dear Mr. van Kempen: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation and assesses a civil penalty of $27,600. It further specifies actions that need to be taken by DCP Midstream, LP, to comply with the pipeline safety regulations. 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 satisfied, as determined by the Director, Southwest Region, this enforcement action will be closed. Service of the Final Order by certified mail is effective upon the date of mailing, 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, Director, Southwest Region, Office of Pipeline Safety, PHMSA Mr. Brent Backes, Group Vice President and General Counsel, DCP Midstream, LP CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

420175032_Final Order__04122018_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 ) DCP Midstream, LP, ) CPF No. 4-2017-5032 ) ) ) Respondent. ) ____________________________________) FINAL ORDER On multiple dates between May and December, 2016, 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 DCP Midstream, LP (DCP or Respondent), in Texas and Oklahoma. DCP is a limited partnership owned by Phillips 66 and Enbridge, Inc., that operates more than 64,000 miles of natural gas liquid (NGL) pipeline and 12 natural gas processing facilities in approximately 16 states.1 As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to Respondent, by letter dated August 24, 2017, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice), which also included warnings pursuant to 49 C.F.R. § 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that DCP had committed four violations of 49 C.F.R. Part 195 and proposed assessing a civil penalty of $27,600 for one alleged violation. The Notice also proposed ordering Respondent to take certain measures to correct the alleged violations. The warning items required no further action but warned the operator to correct the probable violations or face possible future enforcement action. After requesting and receiving an extension of time to respond, DCP responded to the Notice by letter dated October 27, 2017 (Response). The company did not contest the allegations of violation, and agreed to complete certain corrective actions, as provided in the proposed compliance order. Respondent did not request a hearing and therefore has waived its right to one. 1 DCP Midstream website, available at http://www.dcpmidstream.com/getattachment/Utility-Pages/Explore- Footprint/DCP Mid Corp Glance Fact Sheet Q32016 Enbridge Consolidation.pdf.aspx (last accessed January 3, 2018).#

420175032_Final Order__04122018_text.pdf, page 3CPF No. 4-2017-5032 Page 2 FINDINGS OF VIOLATION In its Response, DCP did not contest the allegations in the Notice that it violated 49 C.F.R. Part 195, as follows: Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(i)(4), which states: § 195.452 Pipeline integrity management in high consequence areas. (a) . . . . (i) What preventive and mitigative measures must an operator take to protect the high consequence area? - (1) . . . . (4) Emergency Flow Restricting Devices (EFRD). If an operator determines that an EFRD is needed on a pipeline segment to protect a high consequence area in the event of a hazardous liquid pipeline release, an operator must install the EFRD. In making this determination, an operator must, at least, consider the following factors—the swiftness of leak detection and pipeline shutdown capabilities, the type of commodity carried, the rate of potential leakage, the volume that can be released, topography or pipeline profile, the potential for ignition, proximity to power sources, location of nearest response personnel, specific terrain between the pipeline segment and the high consequence area, and benefits expected by reducing the spill size. The Notice alleged that Respondent violated 49 C.F.R. § 195.452(i)(4) by failing to determine whether EFRDs were needed on two DCP pipeline segments running through high consequence areas (HCAs). Specifically, the Notice alleged that DCP failed to perform an initial evaluation on the company’s Panova to Red River and Red River to Mount Belvieu segments. Both § 195.452(i)(4) and section IP 008 of DCP’s own written Integrity Procedure, IP 008 (version 3.1, dated December 2012), required that DCP consider whether EFRDs should be added as a preventive and mitigative measure on the listed pipeline segments. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.452(i)(4) by failing to determine whether EFRDs were needed on two pipeline segments in order to protect HCAs. Item 5: The Notice alleged that Respondent violated 49 C.F.R. § 195.581, which states, in relevant part: § 195.581 Which pipelines must I protect against atmospheric corrosion and what coating material may I use? (a) You must clean and coat each pipeline or portion of pipeline that is exposed to the atmosphere, except pipelines under paragraph (c) of this section. (b) Coating material must be suitable for the prevention of atmospheric corrosion. The Notice alleged that Respondent violated 49 C.F.R. § 195.581(a) by failing to clean and coat each pipeline that is exposed to the atmosphere. Specifically, the Notice alleged that DCP#

420175032_Final Order__04122018_text.pdf, page 4CPF No. 4-2017-5032 Page 3 discovered numerous instances of deteriorated coating on its pipeline when conducting atmospheric pipe inspections. However, for 40 of the pipeline portions identified as having deteriorated coatings, DCP failed to remediate the deteriorated coatings by cleaning and coating the pipeline. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.581(a) by failing to clean and coat numerous portions of its pipeline that were exposed to the atmosphere. Item 6: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), which states: § 195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) by failing to follow its own manual of written procedures for conducting normal operations and maintenance activities. Specifically, the Notice alleged that DCP failed to follow Section 4 of its Integrity Management Manual – Risk Management Manual, Subsection 4.4.5: Pipeline Facilities Risk Assessment. Subsection 4.4.5 provides, in relevant part, that Respondent must use the checklist in DCP Form 50 to assist in “determining the most credible release scenario and impact on any affected HCAs.” During its inspection, PHMSA noted that DCP had facilities in Teague, Lockwood, and Panova, all of which are in HCA or HCA-could-affect areas. When the PHMSA inspector asked DCP for copies of the Form 50 checklist generated for these three facilities, as required under Subsection 4.4.5, DCP was not able to provide them. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.402(a) by failing to follow its own manual of written procedures for conducting normal operations and maintenance activities. Item 8: The Notice alleged that Respondent violated 49 C.F.R. § 195.573(a)(1), which states: § 195.573 What must I do to monitor external corrosion control? (a) Protected pipelines. You must do the following to determine whether cathodic protection required by this subpart complies with §195.571: (1) Conduct tests on the protected pipeline at least once each calendar year, but with intervals not exceeding 15 months. . . .#

420175032_Final Order__04122018_text.pdf, page 5CPF No. 4-2017-5032 Page 4 The Notice alleged that Respondent violated 49 C.F.R. § 195.573(a)(1) by failing to conduct tests on one of its cathodically protected pipelines at least once each calendar year, but with intervals not exceeding 15 months. Specifically, the Notice alleged that DCP failed to conduct tests at five locations on its 16-inch Lockwood Station to Teague Station pipeline at least once each calendar year, but with intervals not exceeding 15 months. By failing to test at these five locations, DCP was unable to demonstrate adequate levels of cathodic protection under § 195.573(a)(1). Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.573(a)(1) by failing to conduct tests on one of its cathodically protected pipelines at least once per calendar year, but with intervals not exceeding 15 months. 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.2 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 doing 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 $27,600 for the violation in Item 8 above. Item 8: The Notice proposed a civil penalty of $27,600 for Respondent’s violation of 49 C.F.R. § 195.573(a)(1), for failing to conduct tests on one of its cathodically protected pipelines at least once per calendar year, but with intervals not exceeding 15 months. DCP neither contested the allegation nor presented any evidence or argument justifying a reduction in the proposed penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $27,600 for violation of 49 C.F.R. § 195.573(a)(1). In summary, having reviewed the record and considered the assessment criteria for the Item cited above, I assess Respondent a total civil penalty of $27,600. 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 2 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum Civil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).#

420175032_Final Order__04122018_text.pdf, page 6CPF No. 4-2017-5032 Page 5 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 $27,600 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 Items 4, 5, and 6 in the Notice for violations of 49 C.F.R. §§ 195.452(i)(4), 195.581(a), and 195.402(a), respectively. 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. 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: 1. With respect to the violation of § 195.452(i)(4) (Item 4), Respondent must perform a study, based on a current high consequence area list, to determine whether EFRDs are needed on pipeline segments to protect high consequence areas in the event of a hazardous liquid pipeline release to enhance public safety. Respondent must complete this compliance item and submit documentation to the Director within 90 days of receipt of this Order. 2. With respect to the violation of § 195.581(a) (Item 5), Respondent must provide evidence that the 40 identified locations with deteriorated coating have been adequately cleaned and coated. Respondent must complete this compliance item and submit documentation to the Director within 180 days of receipt of this Order. 3. With respect to the violation of § 195.402(a) (Item 6), Respondent must conduct a thorough review using the Form 50 checklist to determine the most credible release scenario and impact on HCAs and HCA-could-affect areas to enhance public safety. Respondent must complete this compliance item and submit documentation to the Director within 90 days of receipt of this Order. 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 and demonstrating good cause for an extension. It is requested that Respondent maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to the Director. It is#

420175032_Final Order__04122018_text.pdf, page 7CPF No. 4-2017-5032 Page 6 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. Failure to comply with this Order may result in the administrative assessment of civil penalties not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), 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. WARNING ITEMS With respect to Items 1, 2, 3, and 7, the Notice alleged probable violations of Part 195 but did not propose a civil penalty or compliance order for these items. Therefore, these are considered to be warning items. The warnings were for: 49 C.F.R. § 195.64(c) (Item 1) ─ Respondent’s alleged failure to notify PHMSA that DCP had divested a pipeline asset; 49 C.F.R. § 195.579(c) (Item 2) ─ Respondent’s alleged failure to perform an inspection of the internal surface of a segment of pipeline removed during a “hot tap;” 49 C.F.R. § 195.402(a) (Item 3) ─ Respondent’s alleged failure to follow its own manual of written procedures with respect to pipeline-assessment scheduling; and 49 C.F.R. § 195.567(c) (Item 7) ─ Respondent’s alleged failure to maintain test lead wires in a condition that enabled DCP to determine whether cathodic protection complied with § 195.571. DCP presented information in its Response showing that it had taken certain actions to address the cited items. If OPS finds a violation of any of these items in a subsequent inspection, Respondent may be subject to future enforcement action. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. April 12, 2018 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

420175032_NOPV PCP PCO_08242017_text.pdf, page 1Official PDFNOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER CERTIFIED MAIL - RETURN RECEIPT REQUESTED August 24, 2017 DCP Midstream Mr. Bent Backes General Counsel and Vice President 370, 17th Street Suite 2500 Denver, CO 80202 CPF 4-2017-5032 Dear Mr. Backes: On multiple dates between the months of May and December 2016, 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 inspected DCP Midstream (DCP) NGL Pipeline systems in Texas and Oklahoma. 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. § 195.64 National Registry of Pipeline and LNG Operators. (c) Changes. Each operator must notify PHMSA electronically through the National Registry of Pipeline and LNG Operators at http://opsweb.phmsa.dot.gov, of certain events.#

420175032_NOPV PCP PCO_08242017_text.pdf, page 2(2) An operator must notify PHMSA of any following event not later than 60 days after the event occurs: (v) The acquisition or divestiture of an existing pipeline facility subject to this part. DCP Southern Hills sold the Galena Park extension (12.1 miles) of the Southern Hills Pipeline System to Phillips 66 on April 22, 2014. A Type D notification (divestiture of asset) is required to filed by no later than June 23, 2014. DCP submitted this notification to PHMSA on June 7, 2016 only after the PHMSA inspector brought this to their attention. 2. §195.579 What must I do to mitigate internal corrosion? (c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect the internal surface of the pipe for evidence of corrosion. If you find internal corrosion requiring corrective action under §195.585, you must investigate circumferentially and longitudinally beyond the removed pipe (by visual examination, indirect method, or both) to determine whether additional corrosion requiring remedial action exists in the vicinity of the removed pipe. DCP Southern Hills failed to perform an inspection of the internal surface of a hot tap coupon from their pipeline system for evidence of corrosion. During the inspection, DCP did not have information or documentation to support that an internal inspection was performed when DCP made a hot tap to connect new Woodford Express Meter Station to the Chitwood lateral pipeline at 2.8 miles southeast from MLV 58C. DCP performed the hot tap January 2015 and a coupon was removed. However, this inspection report was not available, and an internal inspection was not performed during this project. 3. §195. 402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. DCP failed to follow their Integrity Manual. 2#

420175032_NOPV PCP PCO_08242017_text.pdf, page 3DCP’s procedure, IP-002: Integrity Assessment Method Selection states, To select appropriate assessment method, PIPELINE SERVICES DEPARTMENT will:  Conduct a risk assessment and perform information analysis (review leak and repair history, results of previous assessments, exposed pipe reports, and other pertinent information). See Integrity Management Plan – Hazardous Liquids and Integrity Management Plan – Gas Transmission, Section 5 Continual Assessment Process.  Identify risk drivers and applicable threats.  Complete DCP Form 55: Integrity Assessment Method.  Use the decision flow in the flowcharts presented as Figures 1 through 6 in DCP Form 55: Integrity Assessment Method to make a selection. When selecting a specific ILI technology, or when both pressure test and ILI are acceptable as assessment methods, use Tables 1 and 2 as further guidance in making the determination.  Justify and document the reason if different method is chosen than indicated by the flowcharts. Obtain an approval from the DIRECTOR, PIPELINE COMPLIANCE & INTEGRITY.  Document the final assessment method and schedule in the BAP and the IAP.  Inform PIPELINE INSPECTION MANAGER about selected method(s) and proposed assessment schedule. Document results in DCP Midstream Form 55: Integrity Assessment Method. While reviewing DCP’s Integrity Assessment Method, Form 55 dated February 28, 2014, for Southern Hills pipeline, Segment SOH-1 – Jacksboro to Teague, the PHMSA inspector learned that DCP scheduled the next assessment for June 2014. DCP documented the rationale indicating this line is susceptible to SCC, External Corrosion and Third Party Damage. When the PHMSA inspector reviewed the assessment for this pipeline, it was found that it was not assessed until December 2015. As a result, this assessment was late by 18 months. 4. § 195.452 Pipeline integrity management in high consequence areas. (i) What preventative and mitigative measures must an operator take to protect the high consequence area? (4) Emergency Flow Restricting Devices (EFRD). If an operator determines that an EFRD is needed on a pipeline segment to protect a high consequence area in the event of a hazardous liquid pipeline release, an operator must install the EFRD. In making this determination, an operator must, at least, consider the following factors-the swiftness of leak detection and pipeline shutdown capabilities, the type of commodity carried, the rate of potential leakage, the volume that can be released, topography or pipeline profile, the potential for ignition, proximity to power sources, location of nearest response personnel, specific terrain between the pipeline segment and the high consequence area, and benefits expected by reducing the spill size. DCP delayed its process to determine if EFRDs were needed on certain pipeline segments to protect high consequence areas in the event of a hazardous liquid pipeline release.3#

420175032_NOPV PCP PCO_08242017_text.pdf, page 4DCP’s Integrity Procedure, IP 008 (version 3.1 dated December 2012) states preventative and mitigative measures should include consideration of Emergency Flow Restricting Devices (EFRD) or Emergency Flow Valves (EFVs). In general, EFRDs and EFVs are an added optional safety device that has no effect on the flow resulting from a small leak, such as a leak caused by corrosion or a small crack. These valves do not prevent accidents; instead, they help mitigate the consequences of accidents where there has been a substantial or catastrophic line break. Where installed, they are complementary to damage prevention programs, one-call systems, and other pipeline safety efforts that focus on preventing accidents caused by outside forces. In reviewing potential mitigation options, DCP Midstream should consider if automatic shut-off valves or remote control valves represent an efficient means of adding protection to potentially affected high consequence areas. During the inspection, the PHMSA inspector learned that DCP failed to perform the initial EFRD evaluation on the following pipelines: Panova to Red River Red River to Mount Belvieu. 5. §195.581 Which pipelines must I protect against atmospheric corrosion and what coating material may I use? (a) You must clean and coat each pipeline or portion of pipeline that is exposed to the atmosphere, except pipelines under paragraph (c) of this section. DCP did not adequately clean and coat portions of pipeline that were exposed to the atmosphere and at soil-to-air interfaces (transition zone) to protect against atmospheric corrosion. DCP’s standard operating procedure, CORR-5020: Atmospheric Pipe Inspection (dated 10/31/2014), Section 1.1.3 Soil-to-Air Interface states: 1.1.3.1 Inspect all piping that is located at the soil-to-air interface. 1.1.3.1.1 Piping that is located in the soil-to-air interface is especially prone to coating damage. 1.1.3.1.2 If visual examination of the piping at the soil-to-air interface shows evidence of corrosion or coating damage, excavation of the interface may be necessary to complete the inspection. Section 2.2.3 Poor states: Extensive visible deterioration of coating. (21 – 99% deterioration) 2.2.3.1: If left unremediated, pitting corrosion may develop which affect the safe operation of the pipeline before the next scheduled inspection. 4#

420175032_NOPV PCP PCO_08242017_text.pdf, page 5While reviewing records associated with the DCP’s atmospheric corrosion inspection, the PHMSA inspector noted that, at the following locations, DCP failed to remediate poor coating condition prior to the next inspection cycle as noted below: 1) Panova to Cushing, 18” idle pipe, MP 0.449 had poor coating on 9/10/2012. It was not checked again until the time of the inspection. DCP also failed to document the condition of corrosion at this location 2) 3) 4) 5) 6) Panova to Cushing, 18” idle pipe, MP 0.730, had poor coating on 11/14/2013 and 7/14/2016 Panova to Cushing, 18” idle pipe, MP 6.147, had poor transition zone on 11/14/2013 and 7/14/2016 Panova to Cushing, 18” idle pipe, MP 6.147, had poor coating on 11/14/2013 and 7/14/2016 Panova to Cushing, 18” idle pipe, MP 11.632, had poor coating on 9/11/2012 and 7/19/2016 Panova to Cushing, 18” idle pipe, MP 11.632, had poor transition zone on 9/11/2012 and 7/19/2016 7) Panova to Cushing, 18” idle pipe, MP 11.632, was rated as “poor” in corrosion category on 9/11/2012 and 7/19/2016 8) Panova to Cushing, 18” idle pipe, MP 13.480, had poor coating on 11/15/2013 and 7/19/2016 9) Panova to Cushing, 18” idle pipe, MP 13.480, had poor transition zone on 11/15/2013 and 7/19/2016 10) Panova to Cushing, 18” idle pipe, MP 16.999, had poor coating on 9/12/2012 and 7/19/2016 11) Panova to Cushing, 18” idle pipe, MP 16.999, had poor transition zone on 11/14/2013 and 7/19/2016 12) Panova to Cushing, 18” idle pipe, MP 17.559, had poor coating on 9/12/2012 and 7/19/2016 13) Panova to Cushing, 18” idle pipe, MP 17.559, had poor transition zone on 11/14/2013 and 7/19/2016 14) Panova to Cushing, 18” idle pipe, MP 18.265, had poor coating on 11/14/2013 and 7/20/2016 15) Panova to Cushing, 18” idle pipe, MP 18.265, had poor transition zone on 9/12/2012 and 7/20/2016 16) Panova to Cushing, 18” idle pipe, MP 19.290, had poor coating on 9/13/2012 and 8/27/2016 17) Panova to Cushing, 18” idle pipe, MP 19.290, had poor transition zone on 11/14/2013 and 8/27/2016 18) Panova to Cushing, 18” idle pipe, MP 20.517, had poor coating on 9/13/2012 and 7/20/2016 19) Panova to Cushing, 18” idle pipe, MP 20.517, had poor transition zone on 11/14/2013 and 7/20/2016 20) Panova to Cushing, 18” idle pipe, MP 23.383, had poor transition zone on 11/15/2013 and 7/22/2016 21) Panova to Cushing, 18” idle pipe, MP 24.894, had poor coating on 9/14/2012 and 7/22/2016 22) Panova to Cushing, 18” idle pipe, MP 24.894, had poor transition zone on 9/14/2012 and 7/22/2016 23) Panova to Cushing, 18” idle pipe, MP 24.894, was rated as “poor” in corrosion category on 9/14/2012 and 7/22/2016 24) Panova to Cushing, 18” idle pipe, MP 24.894, was rated as “poor” in corrosion category on 9/14/2012 and 7/22/2016 25) Panova to Cushing, 18” idle pipe, MP 28.058, had poor coating on 9/18/2012 and 7/22/2016 5#

420175032_NOPV PCP PCO_08242017_text.pdf, page 626) Panova to Cushing, 18” idle pipe, MP 28.058, had poor transition zone on 11/14/2013 and 7/22/2016 27) Panova to Cushing, 18” idle pipe, MP 31.730, had poor coating on 11/15/2013 and 7/25/2016 28) Panova to Cushing, 18” idle pipe, MP 31.730, had poor transition zone on 11/15/2013 and 7/25/2016 29) Panova to Cushing, 18” idle pipe, MP 32.206, had poor coating on 9/19/2012 and 7/25/2016 30) Panova to Cushing, 18” idle pipe, MP 32.206, had poor transition zone on 9/19/2012 and 7/25/2016 31) Panova to Cushing, 18” idle pipe, MP 35.675, had poor coating on 11/14/2013 and 7/27/2016 32) Panova to Cushing, 18” idle pipe, MP 35.975, had poor transition zone on 11/14/2013 and 7/27/2016 33) Panova to Cushing, 18” idle pipe, MP 35.770, had poor coating on 9/19/2012 and 7/27/2016 34) Panova to Cushing, 18” idle pipe, MP 35.770, had poor transition zone on 11/14/2013 and 7/27/2016 35) Panova to Cushing, 18” idle pipe, MP 44.410, had poor coating on 11/15/2013 and 7/28/2016 36) Panova to Cushing, 18” idle pipe, MP 44.410, had poor transition zone on 11/15/2013 and 7/28/2016 37) Panova to Cushing, 18” idle pipe, MP 44.504, had poor coating on 9/19/2012 and 7/28/2016 38) Panova to Cushing, 18” idle pipe, MP 44.523, had poor coating on 9/19/2012 and 7/28/2016 39) Panova to Cushing, 18” idle pipe, MP 44.523, was rated as “poor” in corrosion category on 9/19/2012 and 7/28/2016 40) Panova to Cushing, 18” idle pipe, MP 44.523, had poor transition zone on 9/19/2012 and 7/28/2016 6. §195. 402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. DCP did not follow their Integrity Manual. DCP’s Integrity Management Manual, Section 4 – Risk Management Manual, Sub Section 4.4.5: Pipeline Facilities Risk Assessment, states: The comprehensive risk assessment process for the pipeline stations includes a thorough review of the incident history of the pipeline stations. One example of the difference between the line pipe and facilities6#

420175032_NOPV PCP PCO_08242017_text.pdf, page 7is that for the line pipe, the primary cause for a release is corrosion, while for a station the primary cause of a release is equipment leaks at pumps, valves and fittings. The checklist in DCP Form 50: Pipeline Facilities Checklist assists in determining the most credible release scenario and impact on any affected HCAs. During the inspection, the PHMSA inspector noted DCP has facilities located at Teague, Lockwood and Panova, all in HCA or in HCA could-affect zones. When the PHMSA inspector requested Form 50: Pipeline Facilities Checklist, DCP was not able to provide it. 7. §195.567 Which pipelines must have test leads and what must I do to install and maintain the leads? (c) Maintenance. You must maintain the test lead wires in a condition that enables you to obtain electrical measurements to determine whether cathodic protection complies with §195.571. DCP failed to maintain all CP test leads in a condition that enabled it to obtain electrical measurements to determine whether cathodic protection complies with §195.571. The December 2013 and September 2014 annual CP surveys at mile post (MP) 42.080 along the 16-inch Jacksboro Station to Teague Station pipeline showed p/s readings of 0.000mV and 0.000mV, respectively. These p/s readings were indicative of a broken test lead. DCP corrected this and determined there was adequate cathodic protection during July 2015 annual survey. 8. §195.573 What must I do to monitor external corrosion control? (a) Protected pipelines. You must do the following to determine whether cathodic protection required by this subpart complies with §195.571: (1) Conduct tests on the protected pipeline at least once each calendar year, but with intervals not exceeding 15 months. However, if tests at those intervals are impractical for separately protected short sections of bare or ineffectively coated pipelines, testing may be done at least once every 3 calendar years, but with intervals not exceeding 39 months. DCP did not conduct tests on the cathodically protected pipeline segments to monitor external corrosion control, at least once each calendar year, but with intervals not exceeding 15 months. During the inspection, DCP provided records that demonstrated that the 16” Lockwood Station to Teague Station pipeline at MP 31.330, 65.840, 88.990, 90.760 and 97.840 were not tested as required by §195.573(a)(1) to demonstrate adequate levels of cathodic protection. MP 31.330 was last surveyed on 12/13/2014 and was not surveyed again until 1/22/2016 MP 65.840 was last surveyed on 12/12/2013 and was not surveyed again until 1/25/2016 7#

420175032_NOPV PCP PCO_08242017_text.pdf, page 8MP 88.990 was last surveyed on 12/12/2013 (no access) and was not surveyed again until 7/28/2015 MP 90.760 was last surveyed on 12/12/2013 and was not surveyed again until 7/28/2015 MP 97.840 was last surveyed on 12/12/2013 and was not surveyed again until 7/28/2015 Proposed Civil Penalty 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. 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 $27,600 as follows: Item number PENALTY 8 $ 27,600 Warning Items With respect to items 1, 2, 3, and 7 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 these item(s). Failure to do so may result in additional enforcement action. Proposed Compliance Order With respect to item 4, 5 and 6 pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to DCP Southern Hills. 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. 8#

420175032_NOPV PCP PCO_08242017_text.pdf, page 9In your correspondence on this matter, please refer to CPF 4-2017-5032 and for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Frank Causey Acting Director, SW Region Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Compliance Proceedings 9#

420175032_NOPV PCP PCO_08242017_text.pdf, page 10PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to DCP Southern Hills (DCP) a Compliance Order incorporating the following remedial requirements to ensure the compliance of DCP with the pipeline safety regulations: 1. 2. 3. 4. 5. In regard to Item Number 4 of the Notice pertaining to DCP failure to determine if EFRDs were needed on pipeline segments to protect high consequence areas in the event of a hazardous liquid pipeline release, DCP must perform a study based on a current high consequence area list to determine that an EFRD is needed on a pipeline segment to protect a high consequence area in the event of a hazardous liquid pipeline release to enhance public safety. In regard to Item Number 5 of the Notice pertaining to inadequately cleaned and coated soil-to-air interfaces on the portions of Panova to Cushing, 18” idle pipeline which is identified in DCP’s atmospheric inspection records (2012 to 2016). DCP must provide evidence when the coating at these locations have been completed to verify that DCP has complied with this compliance order item. In regard to Item Number 6 of the Notice pertaining to DCP’s failure to perform the comprehensive risk assessment process for the pipeline stations that includes a thorough review using the checklist provided in DCP’s Form 50, DCP must determine the most credible release scenario and impact on HCAs to enhance public safety DCP must complete item 1 and 3 in 90 days and item 2 in 180 days. It is requested (not mandated) that DCP maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to the Acting 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. 10#

420175032_Closure Letter_11052018_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED November 5, 2018 Brent L. Backes DCP Midstream General Counsel and Vice President 370, 17th Street, Suite 2500 Denver, Colorado 80202 CPF 4-2017-5032 Dear Mr. Backes: On April 12, 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to DCP Midstream (DCP), a Final Order in the above-referenced case. This Order included a Compliance Order and Civil Penalty assessment. DCP submitted the required information on October 15, 2018. Based on our review of the documentation provided, a subsequent meeting with DCP officials to provide additional clarification on actions taken, and confirmation of payment of the civil penalty, it has been determined that DCP has 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 Region Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration#

420175032_Final Order_04122018.pdf, page 1Official PDFof Transportation U.S. Department 1200 New Jersey Avenue SE Washington DC 20590 Safety Administration Pipeline and Hazardous Materials APR 1 2 2018 Mr. Wouter van Kempen Chairman and CEO DCP Midstream, LP 370 17th Street, Suite 2500 Denver, CO 80202 Re: CPF No. 4-2017-5032 Dear Mr. van Kempen: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of by DCP Midstream, LP, to comply with the pipeline safety regulations. The penalty payment violation and assesses a civil penalty of $27,600. It further specifies actions that need to be taken terms are set forth in the Final Order. When the civil penalty has been paid and the terms of the compliance order satisfied, as determined by the Director, Southwest Region, this enforcement action will be closed. Service of the Final Order by certified mail is effective upon the date of mailing, as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Man Vant Ma Mayberry 4 Associate Administrator for Pipeline Safety Enclosure CC: Ms. Mary McDaniel, Director, Southwest Region, Office of Pipeline Safety, PHMSA Mr. Brent Backes, Group Vice President and General Counsel, DCP Midstream, LP CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

420175032_Final Order_04122018.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 DCP Midstream, LP, CPF No. 4-2017-5032 Respondent. FINAL ORDER On multiple dates between May and December, 2016, 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 DCP Midstream, LP (DCP or Respondent), in Texas and Oklahoma. DCP is a limited partnership owned by Phillips 66 and Enbridge, Inc., that operates more than 64,000 miles of natural gas liquid (NGL) pipeline and 12 natural gas processing facilities in approximately 16 states.! As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to Respondent, by letter dated August 24, 2017, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice), which also included warnings pursuant to 49 C.F.R. § 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that DCP had committed four violations of 49 C.F.R. Part 195 and proposed assessing a civil penalty of $27,600 for one alleged violation. The Notice also proposed ordering Respondent to take certain measures to correct the alleged violations. The warning items required no further action but warned the operator to correct the probable violations or face possible future enforcement action. After requesting and receiving an extension of time to respond, DCP responded to the Notice by letter dated October 27, 2017 (Response). The company did not contest the allegations of violation, and agreed to complete certain corrective actions, as provided in the proposed compliance order. Respondent did not request a hearing and therefore has waived its right to one. ' DCP Midstream website, available at http://www.dcpmidstream.com/getattachment/Utility-Pages/Explore- Footprint/DCP_Mid Corp_ Glance_Fact_ Sheet 032016_Enbridge Consolidation.pdf.aspx (last accessed January 3,#

420175032_Final Order_04122018.pdf, page 3CPF No. 4-2017-5032 Page 2 FINDINGS OF VIOLATION In its Response, DCP did not contest the allegations in the Notice that it violated 49 C.F.R. Part 195, as follows: Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.452(i)(4), which states: § 195.452 Pipeline integrity management in high consequence areas. (a) (i) What preventive and mitigative measures must an operator take to protect the high consequence area? - (1) ... (4) Emergency Flow Restricting Devices (EFRD). If an operator determines that an EFRD is needed on a pipeline segment to protect a high consequence area in the event of a hazardous liquid pipeline release, an operator must install the EFRD. In making this determination, an operator topography or pipeline profile, the potential for ignition, proximity to power sources, location of nearest response personnel, specific terrain between the pipeline segment and the high consequence area, and benefits expected by reducing the spill size. The Notice alleged that Respondent violated 49 C.F.R. § 195.452(i)(4) by failing to determine whether ErDs were needed on two DCP pipeline segments running through high consequence areas (HCAs). Specifically, the Notice alleged that DCP failed to perform an initial evaluation on the company's Panova to Red River and Red River to Mount Belvieu segments. Both § 195.452(i)(4) and section IP 008 of DCP's own written Integrity Procedure, IP 008 (version 3.1, dated December 2012), required that DCP consider whether EFRDs should be added as a preventive and mitigative measure on the listed pipeline segments. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.452(i)(4) by failing to determine whether EFRDs were needed on two pipeline segments in order to protect HCAs. Item 5: The Notice alleged that Respondent violated 49 C.F.R. § 195.581, which states, in relevant part: § 195.581 Which pipelines must I protect against atmospheric corrosion and what coating material may I use? (a) You must clean and coat each pipeline or portion of pipeline that is exposed to the atmosphere, except pipelines under paragraph (c) of this section. (b) Coating material must be suitable for the prevention of atmospheric corrosion. The Notice alleged that Respondent violated 49 C.F.R. § 195.581(a) by failing to clean and coat each pipeline that is exposed to the atmosphere. Specifically, the Notice alleged that DCP#

420175032_Final Order_04122018.pdf, page 4CPF No. 4-2017-5032 Page 3 discovered numerous instances of deteriorated coating on its pipeline when conducting atmospheric pipe inspections. However, for 40 of the pipeline portions identified as having deteriorated coatings, DCP failed to remediate the deteriorated coatings by cleaning and coating the pipeline. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.581(a) by failing to clean and coat numerous portions of its pipeline that were exposed to the atmosphere. Item 6: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), which states: § 195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) by failing to follow its own manual of written procedures for conducting normal operations and maintenance activities. Specifically, the Notice alleged that DCP failed to follow Section 4 of its Integrity Management Manual - Risk Management Manual, Subsection 4.4.5: Pipeline Facilities Risk Assessment. Subsection 4.4.5 provides, in relevant part, that Respondent must use the checklist in DCP Form 50 to assist in "determining the most credible release scenario and impact on any affected HCAs." During its inspection, PHMSA noted that DCP had facilities in Teague, Lockwood, and Panova, all of which are in HCA or HCA-could-affect areas. When the PHMSA inspector asked DCP for copies of the Form 50 checklist generated for these three facilities, as required under Subsection 4.4.5, DCP was not able to provide them. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.402(a) by failing to follow its own manual of written procedures for conducting normal operations and maintenance activities. Item 8: The Notice alleged that Respondent violated 49 C.F.R. § 195.573(a)(1), which states: § 195.573 What must I do to monitor external corrosion control? (a) Protected pipelines. You must do the following to determine whether cathodic protection required by this subpart complies with $195.571: (1) Conduct tests on the protected pipeline at least once each calendar year, but with intervals not exceeding 15 months....#

420175032_Final Order_04122018.pdf, page 5CPF No. 4-2017-5032 Page 4 The Notice alleged that Respondent violated 49 C.F.R. § 195.573(a)(1) by failing to conduct tests on one of its cathodically protected pipelines at least once each calendar year, but with intervals not exceeding 15 months. Specifically, the Notice alleged that DCP failed to conduct tests at five locations on its 16-inch Lockwood Station to Teague Station pipeline at least once each calendar year, but with intervals not exceeding 15 months. By failing to test at these five locations, DCP was unable to demonstrate adequate levels of cathodic protection under § 195.573(a)(1). Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.573(a)(1) by failing to conduct tests on one of its cathodically protected pipelines at least once per calendar year, but with intervals not exceeding 15 months. 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 doing 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 $27,600 for the violation in Item 8 above. Item 8: The Notice proposed a civil penalty of $27,600 for Respondent's violation of 49 C.F.R. § 195.573(a)(1), for failing to conduct tests on one of its cathodically protected pipelines at least once per calendar year, but with intervals not exceeding 15 months. DCP neither contested the allegation nor presented any evidence or argument justifying a reduction in the proposed penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $27,600 for violation of 49 C.F.R. § 195.573(a)(1). In summary, having reviewed the record and considered the assessment criteria for the Item cited above, I assess Respondent a total civil penalty of $27,600. 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 2 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum Civil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).#

420175032_Final Order_04122018.pdf, page 6CPF No. 4-2017-5032 Page 5 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 $27,600 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 Items 4, 5, and 6 in the Notice for violations of 49 C.F.R. §§ 195.452(i)(4), 195.581(a), and 195.402(a), respectively. 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. 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: 1. With respect to the violation of § 195.452(i)(4) (Item 4), Respondent must perform a study, based on a current high consequence area list, to determine whether EFRDs are needed on pipeline segments to protect high consequence areas in the event of a hazardous liquid pipeline release to enhance public safety. Respondent must complete this compliance item and submit documentation to the Director within 90 days of receipt of this Order. 2. With respect to the violation of § 195.581(a) (Item 5), Respondent must provide evidence that the 40 identified locations with deteriorated coating have been adequately cleaned and coated. Respondent must complete this compliance item and submit documentation to the Director within 180 days of receipt of this Order. 3. With respect to the violation of § 195.402(a) (Item 6), Respondent must conduct a thorough review using the Form 50 checklist to determine the most credible release scenario and impact on HAs and HCA-could-affect areas to enhance public safety. Respondent must complete this compliance item and submit documentation to the Director within 90 days of receipt of this Order. 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 and demonstrating good cause for an extension. It is requested that Respondent maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to the Director. It is#

420175032_Final Order_04122018.pdf, page 7CPF No. 4-2017-5032 Page 6 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. Failure to comply with this Order may result in the administrative assessment of civil penalties not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), 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. WARNING ITEMS With respect to Items 1, 2, 3, and 7, the Notice alleged probable violations of Part 195 but did not propose a civil penalty or compliance order for these items. Therefore, these are considered to be warning items. The warnings were for: 49 C.F.R. § 195.64(c) (Item 1) — Respondent's alleged failure to notify PHMSA that DCP had divested a pipeline asset; 49 C.F.R. § 195.579(c) (Item 2) - Respondent's alleged failure to perform an inspection of the internal surface of a segment of pipeline removed during a "hot 49 C.F.R. § 195.402(a) (Item 3) - Respondent's alleged failure to follow its own manual of written procedures with respect to pipeline-assessment scheduling; and 49 C.F.R. § 195.567(c) (Item 7) — Respondent's alleged failure to maintain test lead wires in a condition that enabled DCP to determine whether cathodic protection complied with § 195.571. DCP presented information in its Response showing that it had taken certain actions to address the cited items. If OPS finds a violation of any of these items in a subsequent inspection, Respondent may be subject to future enforcement action. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. Nathan, APR 1 2 2018 Ałan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#