BRAVO PIPELINE COMPANY — Warning Letter

42021031WL_Warning Letter_03092021_(21-203102)_text.pdf, page 1Official PDFWARNING LETTER ELECTRONIC MAIL - RETURN RECEIPT REQUESTED March 9, 2021 Vishal Gupta President & General Manager Bravo Pipeline Company 5 Greenway Plaza, Suite 110 Houston, Texas 77046 CPF 4-2021-031-WL Dear Mr. Gupta: On December 10, 2020, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Bravo Pipeline Company compliance with the National Pipeline Mapping System (NPMS) submittal requirement for calendar year 2019. As a result of the inspection, it is alleged that Bravo Pipeline Company has committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The item inspected and the probable violation is: 1. § 195.61 - National Pipeline Mapping System. (a) … (b) This information must be submitted each year, on or before June 15, representing assets as of December 31 of the previous year. If no changes have occurred since the previous year’s submission, the operator must refer to the information provided in the NPMS Operator Standards manual available at www.npms.phmsa.dot.gov or contact the PHMSA Geographic Information Systems Manager at (202) 366-4595. Bravo Pipeline Company failed to submit the information required in paragraph (a) of § 195.61, on or before June 15, representing its assets as of December 31 of the previous year. Specifically, Bravo Pipeline Company failed to submit 1) Geospatial data, attributes, metadata, and transmittal letter appropriate for use in the National Pipeline Mapping System; 2) the name of and address for the operator; and 3) the name and contact information of a pipeline company employee, to be displayed on a public Web site, who will serve as a contact for questions from the general public about the operator's NPMS data for its assets as of December 31, 2019, by the due date of June 15, 2020.#

42021031WL_Warning Letter_03092021_(21-203102)_text.pdf, page 22 Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679. 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. 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 complete an accurate and acceptable calendar year 2020 NPMS submittal for all of the hazardous liquid pipelines in your calendar year 2020 Annual Report on or before June 15, 2021. Failure to do so may result in Bravo Pipeline Company 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 4-2021-031-WL. 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 cc: Bradey Holland, Lead Plant Operations, Bravo Pipeline Company, bradey_holland@oxy.com#