# OZARK GAS TRANSMISSION, L.L.C — Notice of Amendment

**Citation:** CPF 220071006M  
**Type / status:** enforcement / historical  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2007-04-17

CLOSED notice of amendment citing 192.911, 192.911(c), 192.933(d)(1).

## Document text

Notice of Amendment involving OZARK GAS TRANSMISSION, L.L.C. PHMSA's enforcement data identifies the cited regulations as 192.911,  192.911(c),  192.933(d)(1). The case was opened on 2007-04-17 and is reported as closed as of 2007-06-21. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

220071006M notice letter_04172007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071006M/220071006M%20notice%20letter_04172007.pdf

220071006m notice letter_04172007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071006M/220071006m%20notice%20letter_04172007_text.pdf

220071006M_Operator Response to notice letter_05142007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/220071006M/220071006M_Operator%20Response%20to%20notice%20letter_05142007.pdf

220071006m notice letter_04172007_text.pdf

O
U 5 Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
233 Peachtree Street Sts 600
Atlanta, GA 30303
NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT RE UESTED
Apnl 17, 2007
Mr Tom Williams
Senior Vice President
Ozark Gas Transmission — Atlas Pipehne Mid-Continent, LLC
1437 South Boulder, Suite 1500
Tulsa, OK 74119
CPF 2-2007-1006M
Dear Mr Wilhams
On June 6-8, 2006 and June 20, 2006, representatives of the Pipeline and Hazardous Mateinals
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected
the Ozark Gas Transmission Integnty Management Plan (IMP) in Tulsa, Oklahoma
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
the Ozark Gas Transmission Integrity Management Plan, as described below
1. II192. 911 What are the elements of an integrity management program? An
operator's initial integrity management program begins with a framework (see
tt192. 907) and evolves into a more detaded and comprehensive mtegrtty
management program, as information is gained and incorporated into the
program. An operator must make contmual improvements to its program. The
initial program framework and subsequent program must, at minimum, contain
the elements (a) thru (p) in tf192. 911. (When indicated, refer to ASME/ANSI
B31. 8S (ibr, see tf192. 7) for more detaded mformation on the listed element. )
a The Ozark Gas Transmission (OGT) IMP documentation must have sufficient
detail about IMP processes (e g data gathenng, questionable data) to understand
how a task is performed The details should include the following



~ Who owns/is responsible for the task,
~ What are the goals/ob) ectives of the task,
~ What data/information/resources is required to complete the task,
~ How is the task to be completed,
~ When or how often is the task to be completed,
~ Are key elements to the task completion documented,
~ Where is task documentation stored,
~ Are task outputs/results communicated to key personnel,
~ Is there a method for process improvement (reviews/feedback loops)
Prior to the close of the inspection, OGT updated the Responsibihties Matnx in Section
3 of the IM Program manual and added titles and section numbers in Appendix B to
address the first bullet of this issue The remaining items on this issue remained open at
the close of the inspection
2. (1192. 911(c) What are the elements of an mtegrity management program? An
identification of threats to each covered pipehne segment, which must mclude data
integration and a risk assessment. An operator must use the threat identification
and risk assessment to prioritize covered segments for assessment (11192. 917) and
to evaluate the ments of additional preventive and mitigative measures ((1192. 935)
for each covered segment.
a The IMP Section 6 I 3 2 identifies "typical data sources", aud Section 6 1 3 3
discusses integrating data OGT gathered data for the entire pipehne, not)ust
HCAs The inspection team noted that additional detail was needed on the
processes and procedures (e g IMP-6-003 Section 2 1 6) for identifying threats
and data integration
3. 11192. 933(d)(1) Immediate Repair conditions. An operator's evaluation and
remediation schedule must follow ASME/ANSI B31. S, section 7 in providing for
immediate repair conditions. To maintam safety, an operator must temporardy
reduce operatmg pressure in accordance with paragraph (a) of this section or shut
down the pipehne untd the operator completes the repair of these conditions.
a OGT needs to provide more detail on how the process for discovery of
immediate conditions is implemented, starting with the first receipt of
prehminary assessment information to discovery following final report
information from the pigging vendor Prior to the close of the inspection, OGT
clarified the requirement for pressure reduction and remediation within five days
by modifying Section 6 3 3 I of the IMP to state, "The operator shall examine
these mdications withm a pemod not to exceed five days following determmation
of the condition After examination and evaluation any defect found to require
repair or removal shall be promptly remedkated by repair or removal unless the
operating pressure ts lowered to mitigate the need to repair or remove the
defect " Please provide a copy of the revised procedure to the PHMSA
Southern Region Office



b OGT needs to address how multiple immediate conditions discovered dunng an
assessment covenng multiple covered segments are individually prhoihthzed and
scheduled for remediation Prior to the close of the inspection, OGT modified
Section 2 4 2 of IMP-6-017 to state, "Pmomtize the evaluation and remediation
of mdhvidual anomahes within the HCA segments porn highest to lowest msk
utilizmg the Gas Ph eline Risk Assessment IMP-6-003 procedure " Please
provide a copy of the revised procedure to the PHMSA Southern Region Office
c OGT did not have provisions in their IMP or implementing procedures to
schedule and remediate anomalies ansing from threat conditions that do not
meet the classification criteria of II192 933(c) Pnor to the close of the
inspection, OGT modifie Table 1, Scheduhng Requirements by Type of
Condition, in IMP-6-018 to address this issue by adding the following "Any
mdkcation, anomaly, or other condition that is not hsted m the above
categomzed items that reduces the integmty of the lme such that it warrants
remediation " Please provide a copy of the revised procedure to the PHMSA
Southern Region Office
Res onse to this Notice
Tins Notice is provided pursuant to 49 U S C Ih 60108(a) and 49 C F R Ih 190 237 Enclosed
as part of this Notice is a document entitled Response Options for Pipelme Operators hn
Compliance Proceedings Please refer to this document and note the response options Be
advised that all material you submit in response to this enforcement action is sublect to being
made publicly available If you believe that any portion of your responsive matenal quahfies
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 quahfy for
confidential treatment redacted and an explanation of why you believe the redacted information
quahfies 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
tins Notice and authorizes the Associate Admmistrator for Pipeline Safety to find facts as
alleged in this Notice without further notice to you and to issue a Final Order
If, Mer opportumty for a heanng, your plans or procedures are found inadequate as alleged hn
tlus Notice, you may be ordered to amend your plans or procedures to correct the inadequacies
(49 C F R Ih 190 237) If you are not contesting this Notice, we propose that you submit your
amended procedures to my office within 45 days of receipt of this Notice Ttus period may be
extended by written request for good cause Once the inadequacies identified herein have been
addressed in your amended procedures, this enforcement action will be closed



In correspondence concerning this matter, please refer to CPF 2-2007-1006M and, for each
document you submit, please provide a copy in electronic format whenever possible
Sincerely, (
Linda Daugherty
Director, Southern Region
Pipehne and Hazardous Materials Safety Administration
Enclosure Response Options for Pipelme Operators m Compliance Proceedings

## Provenance

- Official: Yes
- Source: <https://primis.phmsa.dot.gov/enforcement-data/case/220071006M>
- Source ID: `phmsa-enforcement`
- SHA-256: `e3917f71c5a6be432e89dcb79467206b9edf6c71b38cb03884f9bcc1124098d8`
- Retrieved: 2026-08-20T04:44:44.458Z
- Exported: 2026-08-22T23:20:35.728Z
- Document slug: `phmsa-enforcement-220071006m`

### Source metadata

```json
{
  "cpf": "220071006M",
  "operator": "OZARK GAS TRANSMISSION, L.L.C",
  "region": "Southern",
  "pipelineType": "GAS INTERSTATE ONSHORE",
  "caseStatus": "CLOSED",
  "citedSections": [
    "192.911",
    "192.911(c)",
    "192.933(d)(1)"
  ],
  "dataAsOf": "08/04/2026 12PM",
  "caseDataAsOf": "2026-08-04",
  "attachmentCount": 3,
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      "bytes": 139184,
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    {
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  "extractedAgencyDocumentCount": 1,
  "attachmentPolicy": "Official attachment links are retained. Agency-issued documents may also include a verified local PDF and page-level text representation.",
  "jurisdiction": "US",
  "operatorName": "OZARK GAS TRANSMISSION, L.L.C"
}
```
