{"operation":"document","citation":"CPF 12022043NOA","title":"ONEOK TEXAS GAS STORAGE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-04-21","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c), 192.12(d)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022043noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022043noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022043noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022043NOA","body":"Notice of Amendment involving ONEOK TEXAS GAS STORAGE, LLC. PHMSA's enforcement data identifies the cited regulations as 192.12(c),  192.12(d)(4). The case was opened on 2022-04-21 and is reported as closed as of 2022-06-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022043NOA_Closure Letter_06022022_(21-200378).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022043NOA/12022043NOA_Closure%20Letter_06022022_(21-200378).pdf\n\n12022043NOA_Closure Letter_06022022_(21-200378)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022043NOA/12022043NOA_Closure%20Letter_06022022_(21-200378)_text.pdf\n\n12022043NOA_Notice of Amendment_04212022_(21-200378).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022043NOA/12022043NOA_Notice%20of%20Amendment_04212022_(21-200378).pdf\n\n12022043NOA_Notice of Amendment_04212022_(21-200378)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022043NOA/12022043NOA_Notice%20of%20Amendment_04212022_(21-200378)_text.pdf\n\n12022043NOA_Operator Response to Notice_05192022_(21-200378).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022043NOA/12022043NOA_Operator%20Response%20to%20Notice_05192022_(21-200378).pdf\n\n12022043NOA_Closure Letter_06022022_(21-200378)_text.pdf\n\nOVERNIGHT EXPRESS DELIVERY\nJune 2, 2022\nMr. Pierce Norton\nPresident and Chief Executive Officer\nONEOK Texas Gas Storage, LLC\n100 West Fifth Street\nTulsa, Oklahoma 74103\nCPF 1-2022-043-NOA\nDear Mr. Norton:\nFrom August 31, 2021 through September 3, 2021, representatives from the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States\nCode, inspected ONEOK Texas Gas Storage LLC’s (ONEOK) procedures for its Underground\nNatural Gas Facility (UNGSF) Program in Gaines County, Texas. As a result of the inspection,\nONEOK was issued a Notice of Amendment on April 21, 2022, which proposed amendment of\nyour procedures.\nONEOK submitted its amended procedures on May 19, 2022. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\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\n12022043NOA_Notice of Amendment_04212022_(21-200378)_text.pdf\n\nNOTICE OF AMENDMENT\nOVERNIGHT EXPRESS DELIVERY\nApril 21, 2022\nMr. Pierce Norton\nPresident and Chief Executive Officer\nONEOK Texas Gas Storage, LLC\n100 West Fifth Street\nTulsa, Oklahoma 74103\nCPF 1-2022-043-NOA\nDear Mr. Norton:\nFrom August 31, 2021 through September 3, 2021, representatives of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code\ninspected ONEOK Texas Gas Storage LLC’s (ONEOK) procedures for its Underground Natural\nGas Facility (UNGSF) Program in Gaines County, Texas.\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(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.\n\n\n\nCPF 1-2022-043-NOA\nONEOK’s written procedures for conducting operations, maintenance and emergency\npreparedness and response activities were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, ONEOK’s UNGS Surface Casing Pressure Monitoring Procedure did not include a\nprocess to evaluate each annular gas occurrence that exceeds operator-defined threshold levels in\naccordance with API RP 1171, Section 9.3.2, Well Integrity Monitoring (Section 9.3.2).\nSection 9.3.2 states in part, “[t]he operator shall evaluate each annular gas occurrence that exceeds\noperator- or regulatory-defined threshold levels determined from well integrity evaluation and\nfrom risk assessment.”\nDuring the inspection, PHMSA reviewed ONEOK’s UNGS Surface Casing Pressure Monitoring\nProcedure, Section 4.3, Data Analysis and found that it did not include a process to evaluate each\nannular gas occurrence that exceeds operator-defined threshold levels.\nTherefore, ONEOK’s written procedures required by § 192.12(c) were inadequate. ONEOK must\nrevise its procedure to address the deficiency outlined above.\n2. § 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’s written procedures for conducting operations, maintenance, and emergency\npreparedness and response activities were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, ONEOK’s Management of Change (MOC) procedures did not include a process for\noperating personnel to be notified of changes or to be trained, and the training documented,\nwhenever changes are made to the operating procedures in accordance with API RP 1171, Section\n11.12.2, O&M Personnel (Section 11.12.2).\nSection 11.12.2 states in part, “[w]henever changes are made to the operating procedures specified\nin 11.3, operating personnel shall be notified and trained as necessary in the changes and training\ndocumented before operating storage wells and reservoirs.”\nDuring the inspection, PHMSA reviewed ONEOK’s MOC procedures and found that a process\nfor notifying and training operating personnel whenever changes are to be made to the operating\nprocedures was not included.\n12022043NOA_Notice of Amendment_04212022_(21-200378)_text Page 2 of 6\n\n\n\nCPF 1-2022-043-NOA\nTherefore, ONEOK’s written procedures required by § 192.12(c) were inadequate. ONEOK must\nrevise its procedure to address the deficiency outlined above.\n3. § 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’s written procedures for conducting operations, maintenance, and emergency\npreparedness and response activities were inadequate to ensure safe operation of a pipeline facility.\nSpecifically, ONEOK’s Reservoir Storage Integrity Management Plan (RSIMP), Section 7.5.2.2,\nWell Integrity Maintenance, did not include procedures for function testing surface safety valves\nor refer to manufacturer’s recommendations in accordance with API RP 1171, Section 9.3.2\n(Section 9.3.2).\nSection 9.3.2 states in part, “[s]urface and subsurface safety valve systems, where installed, shall\nbe function-tested at least annually. The tests shall be conducted in accordance with\nmanufacturer’s recommendations and the operator’s procedures.”\nPHMSA reviewed ONEOK’s RSIMP, and found that Section 7.5.2.2 stated “[a]nnual function\ntesting of safety valve systems, surface and subsurface, and manually reopened at site after test”\nbut it did not include the procedures to be used to perform the tests or reference the manufacturer’s\nrecommendations.\nTherefore, ONEOK’s written procedures required by § 192.12(c) were inadequate. ONEOK must\nrevise its procedure to address the deficiency outlined above.\n4. § 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\n12022043NOA_Notice of Amendment_04212022_(21-200378)_text Page 3 of 6\n\n\n\nCPF 1-2022-043-NOA\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’s written procedures for carrying out its integrity management program were inadequate\nto ensure safe operation of a pipeline facility. Specifically, ONEOK’s UNGS Risk Management\nPlan (RMP), Section 4.6.2, Preventative and Mitigative Measures (Section 4.6.2) and Section\n4.6.3, Methodology (Section 4.6.3) restated the language in API RP 1171 but did not include\ndetails about the preventative and mitigative measures that were to be used to manage risk in\naccordance with API RP 1171, Section 8.6.2, Methodology (Section 8.6.2).\nSection 8.6.2 states in part, “[t]he operator shall develop P&M measures to manage risks.”\nDuring the inspection, PHMSA reviewed ONEOK’s UNGS RMP, Section 4.6.2 and Section 4.6.3\nand found that they restated the API RP 1171 language, and thus failed to include a process for\ndevelopment of P&M measures needed to manage risk.\nTherefore, ONEOK’s written procedures required by § 192.12(d)(4) were inadequate. ONEOK\nmust revise its procedure to address the deficiency outlined above.\n5. § 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’s written procedures for carrying out its integrity management program were inadequate\nto ensure safe operation of a pipeline facility. Specifically, ONEOK’s UNGS Risk Management\nPlan (RMP), Section 4.3.2, Methodology, did not include a process to assess threat and hazard\ninteractions in accordance with API RP 1171, Section 8.3.2 (Section 8.3.2).\nSection 8.3.2 states in part:\nThe operator shall use available information such as performance data collected through\nthe field history, operations and maintenance (O&M) activities, geotechnical data such as\n12022043NOA_Notice of Amendment_04212022_(21-200378)_text Page 4 of 6\n\n\n\nCPF 1-2022-043-NOA\n6. well logs, engineering data, and completion reports to determine susceptibility to threat\nand hazard-related events and to assess threat and hazard interaction.\nPHMSA reviewed ONEOK’s RMP, and found that Section 4.3.2 stated “[O]NEOK will assess the\npotential threat/hazard interaction, such as the relationship of the Threat of casing damage during\nwell drilling or service work that could exacerbate the corrosion process.” but it did not include a\nprocess to assess interactions of threats and hazards specific to its UNGSFs.\nTherefore, ONEOK’s written procedures required by § 192.12(d)(4) were inadequate. ONEOK\nmust revise its procedure to address the deficiency outlined above.\n§ 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’s written procedures for carrying out its integrity management program were inadequate\nto ensure safe operation of a pipeline facility. Specifically, ONEOK’s Reservoir Storage Integrity\nManagement Plan (RSIMP) did not include the timeline requirement for completing baseline risk\nassessments in accordance with § 192.12(d)(2)1\n.\nDuring the inspection, PHMSA reviewed ONEOK’s RSIMP and found that it did not address the\nbaseline risk assessment timeline requirements outlined in § 192.12(d)(2).\n1 § 192.12 Underground natural gas storage facilities.\n(a) …\n(d)\n(1) …\n(2) Integrity management baseline risk-assessment intervals.\nNo later than March 13, 2024, each UNGSF operator must complete the baseline risk assessments of all reservoirs\nand caverns, and at least 40% of the baseline risk assessments for each of its UNGSF wells (including wellhead\nassemblies), beginning with the highest-risk wells, as identified by the risk analysis process. No later than March 13,\n2027, an operator must complete baseline risk assessments on all its wells (including wellhead assemblies).\nOperators may use prior risk assessments for a well as a baseline (or part of the baseline) risk assessment in\nimplementing its initial integrity management program, so long as the prior assessments meet the requirements of\nAPI RP 1171 (incorporated by reference, see §192.7), section 8, and continue to be relevant and valid for the current\noperating and environmental conditions. When evaluating prior risk-assessment results, operators must account for\nthe growth and effects of indicated defects since the time the assessment was performed.\n12022043NOA_Notice of Amendment_04212022_(21-200378)_text Page 5 of 6\n\n\n\nCPF 1-2022-043-NOA\nTherefore, ONEOK’s written procedures required by § 192.12(d)(4) were inadequate. ONEOK\nmust revise its procedure to address the deficiency outlined above.\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 Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 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 30 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 Texas Gas Storage 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, 840 Bear Tavern Road,\nSuite 300, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF\n1-2022-043-NOA and, for each document you submit, please provide a copy in electronic format\nwhenever possible. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should\nbe sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n12022043NOA_Notice of Amendment_04212022_(21-200378)_text Page 6 of 6","truncated":false,"body_characters":18539}