ONEOK GAS TRANSPORTATION, LLC — Notice of Amendment

party submissionOfficial PDF120180005M_Operator Response to Notice_11092018.pdf#

120180005M_Closure Letter_04182019_text.pdf, page 1Official PDFOVERNIGHT EXPRESS DELIVERY April 18, 2019 Mr. Wesley Dunbar VP, Natural Gas Pipelines Operations ONEOK Gas Transportation, LLC 100 West Fifth Street Tulsa, OK 74103 CPF 1-2018-0005M Dear Mr. Dunbar: From April 5 – 8, 2018, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of Title 49 of the United States Code inspected ONEOK Gas Transportation, LLC’s (ONEOK’s) procedures for Functional Integrity of Underground Natural Gas Storage in Tulsa, Oklahoma. Specifically, the Edmond Storage field in Edmond, Oklahoma was inspected. As a result of the inspection, ONEOK was issued a Notice of Amendment (NOA) on October 29, 2018, which proposed amendment of its procedures. On December 26, 2018, ONEOK responded to the NOA and submitted its amended procedures. My staff reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment have been corrected. This letter is to inform you no further action is necessary, and this case is now closed. Thank you for your cooperation. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration#

120180005M_Notice of Amendment_10292018_text.pdf, page 1Official PDFNOTICE OF AMENDMENT OVERNIGHT EXPRESS DELIVERY October 29, 2018 Mr. Wes Christensen Senior Vice President, Operations ONEOK Gas Transportation, LLC 100 West Fifth Street Tulsa, OK 74103 CPF 1-2018-0005M Dear Mr. Christensen: From April 5 – 8, 2018 a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected ONEOK Gas Transportation, LLC’s (ONEOK’s) procedures for Functional Integrity of Underground Natural Gas Storage in Tulsa, Oklahoma. Specifically, the Edmond Storage field in Edmond, Oklahoma was inspected. On the basis of the inspection, PHMSA has identified the apparent inadequacies found within ONEOK’s plans or procedures, as described below: 1. § 192.12 Underground natural gas storage facilities. (e) Operators of underground gas storage facilities must establish and follow written procedures for operations, maintenance, and emergencies implementing the requirements of API RP 1170 and API RP 1171, as required under this section, including the effective dates as applicable, and incorporate such procedures into their written procedures for operations, maintenance, and emergencies established pursuant to § 192.605. ONEOK’s written procedures for operations, maintenance and emergencies implementing the requirements of API RP 1171 were inadequate. Specifically, ONEOK’s written procedures for annular pressure monitoring did not specify that ONEOK must monitor all types of wells for annular pressures in accordance with API RP 1171, Section 9.3.2, Well Integrity Monitoring. ONEOK informed PHMSA that only observation type wells were monitored for annular pressures.#

120180005M_Notice of Amendment_10292018_text.pdf, page 2CPF 1-2018-0005M 2. § 192.12 Underground natural gas storage facilities. (e) Operators of underground gas storage facilities must establish and follow written procedures for operations, maintenance, and emergencies implementing the requirements of API RP 1170 and API RP 1171, as required under this section, including the effective dates as applicable, and incorporate such procedures into their written procedures for operations, maintenance, and emergencies established pursuant to § 192.605. ONEOK’s written procedures for operations, maintenance and emergencies implementing the requirements of API RP 1171 were inadequate. Specifically, ONEOK’s written procedures for thresholds for annular pressure monitoring did not define thresholds for annular pressures in accordance with API RP 1171, Section 9.3.2, Well Integrity Monitoring. Thresholds are necessary to be defined to know if and when further evaluations are necessary for annular pressures. 3. § 192.12 Underground natural gas storage facilities. (e) Operators of underground gas storage facilities must establish and follow written procedures for operations, maintenance, and emergencies implementing the requirements of API RP 1170 and API RP 1171, as required under this section, including the effective dates as applicable, and incorporate such procedures into their written procedures for operations, maintenance, and emergencies established pursuant to § 192.605. ONEOK’s written procedures for operations, maintenance and emergencies implementing the requirements of API RP 1171 were inadequate. Specifically, ONEOK’s written procedures for emergency responses did not reference its application to underground natural gas storage facilities in accordance with API RP 1171, Section 10.6.1, Emergency Preparedness/Emergency Response Plan. ONEOK’s emergency response plan only alluded to gas transmission pipeline facilities. 4. § 192.12 Underground natural gas storage facilities. (e) Operators of underground gas storage facilities must establish and follow written procedures for operations, maintenance, and emergencies implementing the requirements of API RP 1170 and API RP 1171, as required under this section, including the effective dates as applicable, and incorporate such procedures into their written procedures for operations, maintenance, and emergencies established pursuant to § 192.605. ONEOK’s written procedures for operations, maintenance and emergencies implementing the requirements of API RP 1171, were inadequate. Specifically, ONEOK’s procedures for operations, maintenance, and emergencies (OM&E) were inadequate because the OM&E manual was incomplete and not finalized, as required to be completed by January 18, 2018. Written procedures for the operations and maintenance manual were required by January 18, 2018, in accordance with § 192.12(d). During the inspection, ONEOK presented procedures for “Wellhead Valve Inspection and Maintenance Procedure” that were incomplete and in “DRAFT” form. 120180005M_Notice of Amendment_10292018_text Page 2 of 3#

120180005M_Notice of Amendment_10292018_text.pdf, page 3CPF 1-2018-0005M Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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. 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). Following the receipt of this Notice, you have 30 days to submit written comments, revised procedures, or a request for a hearing under §190.211. 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 an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 60 days of receipt of this Notice. This 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. It is requested (not mandated) that ONEOK Gas Transportation, LLC maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 1-2018-0005M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Robert Burrough Director, Eastern Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 120180005M_Notice of Amendment_10292018_text Page 3 of 3#