# ONEOK GAS TRANSPORTATION, LLC — Notice of Amendment

- **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:** Not available
- **summary:** CLOSED notice of amendment citing 192.12(e).
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-120180005m.md
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- **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.

Official case documents:

120180005M_Closure Letter_04182019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180005M/120180005M_Closure%20Letter_04182019.pdf

120180005M_Closure Letter_04182019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180005M/120180005M_Closure%20Letter_04182019_text.pdf

120180005M_Notice of Amendment_10292018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180005M/120180005M_Notice%20of%20Amendment_10292018.pdf

120180005M_Notice of Amendment_10292018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180005M/120180005M_Notice%20of%20Amendment_10292018_text.pdf

120180005M_Operator Response to Notice_11092018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/120180005M/120180005M_Operator%20Response%20to%20Notice_11092018.pdf

120180005M_Closure Letter_04182019_text.pdf

OVERNIGHT 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

NOTICE 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.



CPF 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
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CPF 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
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