{"operation":"document","citation":"CPF 12022042WL","title":"ONEOK TEXAS GAS STORAGE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-04-07","effective_on":null,"summary":"CLOSED warning letter citing 192.12(b)(2), 192.12(c), 192.12(d)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022042wl.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022042wl.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022042wl","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022042WL","body":"Warning Letter involving ONEOK TEXAS GAS STORAGE, LLC. PHMSA's enforcement data identifies the cited regulations as 192.12(b)(2),  192.12(c),  192.12(d)(4). The case was opened on 2022-04-07 and is reported as closed as of 2022-04-07. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022042WL_Warning Letter_04072022_(21-200378).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022042WL/12022042WL_Warning%20Letter_04072022_(21-200378).pdf\n\n12022042WL_Warning Letter_04072022_(21-200378)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022042WL/12022042WL_Warning%20Letter_04072022_(21-200378)_text.pdf\n\n12022042WL_Warning Letter_04072022_(21-200378)_text.pdf\n\nWARNING LETTER\nOVERNIGHT EXPRESS DELIVERY\nApril 7, 2022\nMr. Pierce Norton\nPresident and Chief Executive Officer\nONEOK Texas Gas Storage, LLC\n100 West Fifth Street\nTulsa, Oklahoma 74103\nCPF 1-2022-042-WL\nDear Mr. Norton:\nFrom August 31 through September 3, 2021, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\n(U.S.C.) inspected ONEOK Texas Gas Storage LLC’s (ONEOK) Felmac Storage Facility, Loop\nStorage Facility and Salado Storage Facility in Gaines County, Texas.\nAs a result of the inspection, it is alleged that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected\nand the probable violations are:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) …\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see §192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nONEOK failed to meet the provisions of API RP 1171, Section 9. Specifically, ONEOK failed to\n\n\n\nCPF 1-2022-042-WL\ntest the operation of the master valve and wellhead pipeline isolation valve at least annually for\nproper function and ability to isolate the well in accordance with API RP 1171, Section 9.3.2\n(Section 9.3.2).\nSection 9.3.2 states in part, “The operator shall test the operation of the master valve and wellhead\npipeline isolation valve at least annually for proper function and ability to isolate the well.”\nDuring the inspection, ONEOK was not able to provide test records of the operation of the\nwellhead master valves and wellhead pipeline isolation valves for Felmac Storage for 2019 and\n2020, and for Loop Storage for 2018 through 2020.\nTherefore, ONEOK failed to meet the provisions of Section 9.3.2.\n2. § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) …\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see §192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\nONEOK failed to meet the provisions of API RP 1171, Section 9. Specifically, ONEOK failed to\nperform function tests of surface safety valves in accordance with API RP 1171, Section 9.3.2\n(Section 9.3.2).\nSection 9.3.2 states in part, “Surface and subsurface safety valve systems, where installed, shall be\nfunction-tested at least annually.”\nDuring the inspection, ONEOK was not able to provide surface safety valve function test records\nfor Felmac Storage for 2020.\nTherefore, ONEOK failed to meet the provisions of Section 9.3.2.\n3. § 192.12 Underground natural gas storage facilities.\n(a) …\n(b) Depleted hydrocarbon and aquifer reservoir UNGSFs.\n(1) …\n(2) Each UNGSF that uses a depleted hydrocarbon reservoir or an\naquifer reservoir for natural gas storage and was constructed on or\nbefore July 18, 2017, must meet the provisions of API RP 1171\n(incorporated by reference, see §192.7), sections 8, 9, 10, and 11, and\nparagraph (c) of this section, by January 18, 2018, and must meet all\nprovisions of paragraph (d) of this section by March 13, 2021.\n12022042WL_Warning Letter_04072022_(21-200378)_text Page 2 of 6\n\n\n\nCPF 1-2022-042-WL\nONEOK failed to meet the provisions of API RP 1171, Section 9. Specifically, ONEOK failed to\nperform annual visual wellhead assembly inspections for leaks in accordance with API RP 1171,\nSection 9.3.2 (Section 9.3.2).\nSection 9.3.2 states in part, “The operator shall visually inspect each wellhead assembly at least\nannually for leaks.”\nDuring the inspection, ONEOK was not able to provide records of its annual visual wellhead\nassembly inspections for leaks for Felmac Storage in 2019 and 2020 and for Loop Storage from\n2018 through 2021.\nTherefore, ONEOK failed to meet the provisions of Section 9.3.2.\n4. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\nONEOK failed to meet the requirements of § 192.12(c). Specifically, ONEOK failed to review\nand update its operations and maintenance (O&M) manuals and blowout contingency plan (BCP)\nat intervals not to exceed 15 months, but at least each calendar year.\nDuring the inspection, PHMSA found that ONEOK’s UNGS Annual Wellsite Inspection\nProcedure, UNGS Wellhead Valve Inspection and Maintenance Procedure and BCP were not\nreviewed and updated in 2020. The UNGS Annual Wellsite Inspection Procedure had an issue date\nof 10/15/2019 and a revision date of 05/06/2021. The UNGS Wellhead Valve Inspection and\nMaintenance Procedure had revision dates of 10/15/2018, 12/01/2018, 02/24/2021 and\n05/06/2021.\nTherefore, ONEOK failed to meet the requirements of § 192.12(c).\n5. § 192.12 Underground natural gas storage facilities.\n(a) …\n12022042WL_Warning Letter_04072022_(21-200378)_text Page 3 of 6\n\n\n\nCPF 1-2022-042-WL\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\nONEOK failed to follow of its UNGS Wellhead Valve Inspection and Maintenance Procedure,\nSection 4. Specifically, ONEOK failed to document the actions taken after wellhead valves failed\nto hold pressure in accordance with its UNGS Wellhead Valve Inspection and Maintenance\nProcedure, Section 4.1.5 (Section 4.1.5).\nSection 4.1.5 states in part, “Valves that are found partially or totally inoperable shall be repaired\nor replaced as soon as possible.”\nDuring the inspection, ONEOK presented records of valves failing to hold pressure for Felmac\nStorage and Loop Storage. However, there was no documentation available of the actions taken\nafter the failure was discovered.\nTherefore, ONEOK failed to meet the provisions of Section 4.1.5.\n6. § 192.12 Underground natural gas storage facilities.\n(a) …\n(d) Integrity management program--\n(1) …\n(4) Integrity management procedures and recordkeeping. Each\nUNGSF operator must establish and follow written procedures to carry\nout its integrity management program under API RP 1171\n(incorporated by reference, see § 192.7), section 8 (\"Risk Management\nfor Gas Storage Operations\"), and this paragraph (d). The operator\nmust also maintain, for the useful life of the UNGSF, records that\ndemonstrate compliance with the requirements of this paragraph (d).\nThis includes records developed and used in support of any\nidentification, calculation, amendment, modification, justification,\ndeviation, and determination made, and any action taken to implement\nand evaluate any integrity management program element.\nONEOK failed to follow its Reservoir Storage Integrity Management Plan (RSIMP), Section 9.\nSpecifically, ONEOK failed to update the Task-Op risk model with data collected in 2019 in\naccordance with RSIMP, Section 9.3, Triggering Events (Section 9.3) and Section 9.5.4 (Section\n9.5.4).\n12022042WL_Warning Letter_04072022_(21-200378)_text Page 4 of 6\n\n\n\nCPF 1-2022-042-WL\nSection 9.3 stated in part:\nONEOK shall perform a risk data review on each UGS reservoir facility after the\nfollowing events, but at least once every five (5) years. If a change in risk data is\nidentified, the risk assessment process shall be performed. The events referenced above\ninclude, but are not limited to:\n• Functional integrity assessment completion (See Section 7.0 of this IMP);\n• Identification of leaks;\n• Identification of new threats and/or changing conditions; and\n• Other events identified as problematic by the Underground Storage Engineer.\nAdditional P&MM activity evaluations may be performed upon risk assessment\ncompletion by the Underground Storage Engineering team.\nSection 9.5.4 stated in part, “UGS reservoir facility risk assessment data shall be reviewed and\nupdated in a timeframe not to exceed twelve (12) months following a triggering event.”\nDuring the inspection, ONEOK presented its Task-Op risk model to demonstrate risk\ndetermination and stated that the risk model had not been updated with data collected in 2019. The\ndata included casing inspection results and barrier installations at some well sites.\nTherefore, ONEOK failed to follow its RSIMP, Section 9.3 and Section 9.5.4, as required by\n§ 192.12(d)(4).\nUnder 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed\n$225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related\nseries of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021,\nthe maximum penalty may not exceed $222,504 per violation per day the violation persists, up to\na maximum of $2,225,034 for a related series of violations. For violation occurring on or after\nJuly 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per\nviolation per day the violation persists, up to a maximum of $2,186,465 for a related series of\nviolations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the\nmaximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to\nexceed $2,132,679. For violation occurring on or after November 2, 2015 and before November\n27, 2018, the maximum penalty may not exceed $209,002 per violation per day, with a maximum\npenalty not to exceed $2,090,022.\nWe have reviewed the circumstances and supporting documents involved in this case and have\ndecided not to conduct additional enforcement action or penalty assessment proceedings at this\ntime. We advise you to correct the items identified in this letter. Failure to do so will result in\nONEOK Texas Gas Storage, LLC being subject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 1-2022-042-WL. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\n12022042WL_Warning Letter_04072022_(21-200378)_text Page 5 of 6\n\n\n\nCPF 1-2022-042-WL\nyou believe qualify for confidential treatment redacted and an explanation of why you believe the\nredacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n12022042WL_Warning Letter_04072022_(21-200378)_text Page 6 of 6","truncated":false,"body_characters":13056}