NOBLE MIDSTREAM SERVICES, LLC — Warning Letter

420195014W_Warning Letter_10012019_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED October 1, 2019 Terry Gerhart Chief Executive Officer Noble Midstream Services, LLC 1001 Noble Energy Way Houston, Texas 77070 CPF 4-2019-5014W Dear Mr. Gerhart: On September 25, 2017, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) reviewed the Noble Midstream Services, LLC (Noble Midstream) Operator Registry Notification F- 20170925-16680. As a result of the review, it is alleged that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item review and the probable violation is: 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. (1) An operator must notify PHMSA of any of the following events not later than 60 days before the event occurs: (ii) Construction of 10 or more miles of a new or replacement hazardous liquid or carbon dioxide pipeline;#

420195014W_Warning Letter_10012019_text.pdf, page 2Noble Midstream Services, LLC failed to notify PHMSA of the construction of 10 or more miles of new hazardous liquid pipeline no later than 60 days before the event occurred. Noble Midstream Services, LLC notified PHMSA of the construction of 25 miles of hazardous liquids pipelines through the Operator Registry Notification F-20170925-16680. The notification was dated September 25, 2017, listing an anticipated start date of October 16, 2017. The Notification was filed 21 days prior to the anticipated start date which is less than the 60-day requirement. Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $213,268 per violation per day the violation persists, up to a maximum of $2,132,679 for a related series of violations. For violation occurring on or after November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. For violations occurring prior to November 2, 2015, the maximum penalty may not exceed $200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a related series of violations. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct the item(s) identified in this letter. Failure to do so will result in Noble Midstream being subject to additional enforcement action. No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 4-2019-5014W. Be advised that all material you submit in response to this enforcement action is subject to being made publicly available. If you believe that any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the complete original document you must provide a second copy of the document with the portions you believe qualify for confidential treatment redacted and an explanation of why you believe the redacted information qualifies for confidential treatment under 5 U.S.C. 552(b). Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration 2#