{"operation":"document","citation":"CPF 120180005M","title":"ONEOK GAS TRANSPORTATION, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-10-29","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(e).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-120180005m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-120180005m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-120180005m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/120180005M","body":"Notice of Amendment involving ONEOK GAS TRANSPORTATION, LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(e). The case was opened on 2018-10-29 and is reported as closed as of 2019-04-18. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n120180005M_Closure Letter_04182019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180005M/120180005M_Closure%20Letter_04182019.pdf\n\n120180005M_Closure Letter_04182019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180005M/120180005M_Closure%20Letter_04182019_text.pdf\n\n120180005M_Notice of Amendment_10292018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180005M/120180005M_Notice%20of%20Amendment_10292018.pdf\n\n120180005M_Notice of Amendment_10292018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180005M/120180005M_Notice%20of%20Amendment_10292018_text.pdf\n\n120180005M_Operator Response to Notice_11092018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180005M/120180005M_Operator%20Response%20to%20Notice_11092018.pdf\n\n120180005M_Closure Letter_04182019_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nApril 18, 2019\nMr. Wesley Dunbar\nVP, Natural Gas Pipelines Operations\nONEOK Gas Transportation, LLC\n100 West Fifth Street\nTulsa, OK 74103\nCPF 1-2018-0005M\nDear Mr. Dunbar:\nFrom April 5 – 8, 2018, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of Title 49 of the United States Code inspected\nONEOK Gas Transportation, LLC’s (ONEOK’s) procedures for Functional Integrity of\nUnderground Natural Gas Storage in Tulsa, Oklahoma. Specifically, the Edmond Storage field in\nEdmond, Oklahoma was inspected.\nAs a result of the inspection, ONEOK was issued a Notice of Amendment (NOA) on October 29,\n2018, which proposed amendment of its procedures. On December 26, 2018, ONEOK responded\nto the NOA and submitted its amended procedures. My staff reviewed the amended procedures,\nand it appears that the inadequacies outlined in this Notice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary, and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\n\n120180005M_Notice of Amendment_10292018_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nOctober 29, 2018\nMr. Wes Christensen\nSenior Vice President, Operations\nONEOK Gas Transportation, LLC\n100 West Fifth Street\nTulsa, OK 74103\nCPF 1-2018-0005M\nDear Mr. Christensen:\nFrom April 5 – 8, 2018 a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected ONEOK\nGas Transportation, LLC’s (ONEOK’s) procedures for Functional Integrity of Underground\nNatural Gas Storage in Tulsa, Oklahoma. Specifically, the Edmond Storage field in\nEdmond, Oklahoma was inspected.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nONEOK’s plans or procedures, as described below:\n1. § 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nONEOK’s written procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1171 were inadequate. Specifically, ONEOK’s written procedures for\nannular pressure monitoring did not specify that ONEOK must monitor all types of wells for\nannular pressures in accordance with API RP 1171, Section 9.3.2, Well Integrity Monitoring.\nONEOK informed PHMSA that only observation type wells were monitored for annular pressures.\n\n\n\nCPF 1-2018-0005M\n2. § 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nONEOK’s written procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1171 were inadequate. Specifically, ONEOK’s written procedures for\nthresholds for annular pressure monitoring did not define thresholds for annular pressures in\naccordance with API RP 1171, Section 9.3.2, Well Integrity Monitoring. Thresholds are necessary\nto be defined to know if and when further evaluations are necessary for annular pressures.\n3. § 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nONEOK’s written procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1171 were inadequate. Specifically, ONEOK’s written procedures for\nemergency responses did not reference its application to underground natural gas storage facilities\nin accordance with API RP 1171, Section 10.6.1, Emergency Preparedness/Emergency Response\nPlan. ONEOK’s emergency response plan only alluded to gas transmission pipeline facilities.\n4. § 192.12 Underground natural gas storage facilities.\n(e) Operators of underground gas storage facilities must establish and follow written\nprocedures for operations, maintenance, and emergencies implementing the\nrequirements of API RP 1170 and API RP 1171, as required under this section,\nincluding the effective dates as applicable, and incorporate such procedures into their\nwritten procedures for operations, maintenance, and emergencies established\npursuant to § 192.605.\nONEOK’s written procedures for operations, maintenance and emergencies implementing the\nrequirements of API RP 1171, were inadequate. Specifically, ONEOK’s procedures for operations,\nmaintenance, and emergencies (OM&E) were inadequate because the OM&E manual was\nincomplete and not finalized, as required to be completed by January 18, 2018.\nWritten procedures for the operations and maintenance manual were required by January 18, 2018,\nin accordance with § 192.12(d). During the inspection, ONEOK presented procedures for\n“Wellhead Valve Inspection and Maintenance Procedure” that were incomplete and in “DRAFT”\nform.\n120180005M_Notice of Amendment_10292018_text Page 2\nof 3\n\n\n\nCPF 1-2018-0005M\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 60 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that ONEOK Gas Transportation, LLC maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Robert Burrough, Director,\nEastern Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 1-2018-0005M and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n120180005M_Notice of Amendment_10292018_text Page 3\nof 3","truncated":false,"body_characters":9698}