# NOBLE MIDSTREAM SERVICES, LLC — Warning Letter

- **operation:** document
- **citation:** CPF 420195014W
- **title:** NOBLE MIDSTREAM SERVICES, LLC — Warning Letter
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-10-01
- **effective on:** Not available
- **summary:** CLOSED warning letter citing 195.64(c)(1)(ii).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-420195014w.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420195014w.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420195014w
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420195014W
**body:**

Warning Letter involving NOBLE MIDSTREAM SERVICES, LLC. PHMSA's enforcement data identifies the cited regulation as 195.64(c)(1)(ii). The case was opened on 2019-10-01 and is reported as closed as of 2019-10-01. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420195014W_Warning Letter_10012019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195014W/420195014W_Warning%20Letter_10012019.pdf

420195014W_Warning Letter_10012019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420195014W/420195014W_Warning%20Letter_10012019_text.pdf

420195014W_Warning Letter_10012019_text.pdf

WARNING 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;



Noble 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
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