# ONEOK TEXAS GAS STORAGE, LLC — Notice of Amendment

- **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:** Not available
- **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.

Official case documents:

12022043NOA_Closure Letter_06022022_(21-200378).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022043NOA/12022043NOA_Closure%20Letter_06022022_(21-200378).pdf

12022043NOA_Closure Letter_06022022_(21-200378)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022043NOA/12022043NOA_Closure%20Letter_06022022_(21-200378)_text.pdf

12022043NOA_Notice of Amendment_04212022_(21-200378).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022043NOA/12022043NOA_Notice%20of%20Amendment_04212022_(21-200378).pdf

12022043NOA_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

12022043NOA_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

12022043NOA_Closure Letter_06022022_(21-200378)_text.pdf

OVERNIGHT EXPRESS DELIVERY
June 2, 2022
Mr. Pierce Norton
President and Chief Executive Officer
ONEOK Texas Gas Storage, LLC
100 West Fifth Street
Tulsa, Oklahoma 74103
CPF 1-2022-043-NOA
Dear Mr. Norton:
From August 31, 2021 through September 3, 2021, representatives from the Pipeline and
Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States
Code, inspected ONEOK Texas Gas Storage LLC’s (ONEOK) procedures for its Underground
Natural Gas Facility (UNGSF) Program in Gaines County, Texas. As a result of the inspection,
ONEOK was issued a Notice of Amendment on April 21, 2022, which proposed amendment of
your procedures.
ONEOK submitted its amended procedures on May 19, 2022. 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

12022043NOA_Notice of Amendment_04212022_(21-200378)_text.pdf

NOTICE OF AMENDMENT
OVERNIGHT EXPRESS DELIVERY
April 21, 2022
Mr. Pierce Norton
President and Chief Executive Officer
ONEOK Texas Gas Storage, LLC
100 West Fifth Street
Tulsa, Oklahoma 74103
CPF 1-2022-043-NOA
Dear Mr. Norton:
From August 31, 2021 through September 3, 2021, representatives of the Pipeline and Hazardous
Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code
inspected ONEOK Texas Gas Storage LLC’s (ONEOK) procedures for its Underground Natural
Gas Facility (UNGSF) Program in Gaines County, Texas.
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.
(a) …
(c) Procedural manuals. Each operator of a UNGSF must prepare
and follow for each facility one or more manuals of written procedures
for conducting operations, maintenance, and emergency preparedness
and response activities under paragraphs (a) and (b) of this section.
Each operator must keep records necessary to administer such
procedures and review and update these manuals at intervals not
exceeding 15 months, but at least once each calendar year. Each
operator must keep the appropriate parts of these manuals accessible
at locations where UNGSF work is being performed. Each operator
must have written procedures in place before commencing operations
or beginning an activity not yet implemented.



CPF 1-2022-043-NOA
ONEOK’s written procedures for conducting operations, maintenance and emergency
preparedness and response activities were inadequate to ensure safe operation of a pipeline facility.
Specifically, ONEOK’s UNGS Surface Casing Pressure Monitoring Procedure did not include a
process to evaluate each annular gas occurrence that exceeds operator-defined threshold levels in
accordance with API RP 1171, Section 9.3.2, Well Integrity Monitoring (Section 9.3.2).
Section 9.3.2 states in part, “[t]he operator shall evaluate each annular gas occurrence that exceeds
operator- or regulatory-defined threshold levels determined from well integrity evaluation and
from risk assessment.”
During the inspection, PHMSA reviewed ONEOK’s UNGS Surface Casing Pressure Monitoring
Procedure, Section 4.3, Data Analysis and found that it did not include a process to evaluate each
annular gas occurrence that exceeds operator-defined threshold levels.
Therefore, ONEOK’s written procedures required by § 192.12(c) were inadequate. ONEOK must
revise its procedure to address the deficiency outlined above.
2. § 192.12 Underground natural gas storage facilities.
(a) …
(c) Procedural manuals. Each operator of a UNGSF must prepare
and follow for each facility one or more manuals of written procedures
for conducting operations, maintenance, and emergency preparedness
and response activities under paragraphs (a) and (b) of this section.
Each operator must keep records necessary to administer such
procedures and review and update these manuals at intervals not
exceeding 15 months, but at least once each calendar year. Each
operator must keep the appropriate parts of these manuals accessible
at locations where UNGSF work is being performed. Each operator
must have written procedures in place before commencing operations
or beginning an activity not yet implemented.
ONEOK’s written procedures for conducting operations, maintenance, and emergency
preparedness and response activities were inadequate to ensure safe operation of a pipeline facility.
Specifically, ONEOK’s Management of Change (MOC) procedures did not include a process for
operating personnel to be notified of changes or to be trained, and the training documented,
whenever changes are made to the operating procedures in accordance with API RP 1171, Section
11.12.2, O&M Personnel (Section 11.12.2).
Section 11.12.2 states in part, “[w]henever changes are made to the operating procedures specified
in 11.3, operating personnel shall be notified and trained as necessary in the changes and training
documented before operating storage wells and reservoirs.”
During the inspection, PHMSA reviewed ONEOK’s MOC procedures and found that a process
for notifying and training operating personnel whenever changes are to be made to the operating
procedures was not included.
12022043NOA_Notice of Amendment_04212022_(21-200378)_text Page 2 of 6



CPF 1-2022-043-NOA
Therefore, ONEOK’s written procedures required by § 192.12(c) were inadequate. ONEOK must
revise its procedure to address the deficiency outlined above.
3. § 192.12 Underground natural gas storage facilities.
(a) …
(c) Procedural manuals. Each operator of a UNGSF must prepare
and follow for each facility one or more manuals of written procedures
for conducting operations, maintenance, and emergency preparedness
and response activities under paragraphs (a) and (b) of this section.
Each operator must keep records necessary to administer such
procedures and review and update these manuals at intervals not
exceeding 15 months, but at least once each calendar year. Each
operator must keep the appropriate parts of these manuals accessible
at locations where UNGSF work is being performed. Each operator
must have written procedures in place before commencing operations
or beginning an activity not yet implemented.
ONEOK’s written procedures for conducting operations, maintenance, and emergency
preparedness and response activities were inadequate to ensure safe operation of a pipeline facility.
Specifically, ONEOK’s Reservoir Storage Integrity Management Plan (RSIMP), Section 7.5.2.2,
Well Integrity Maintenance, did not include procedures for function testing surface safety valves
or refer to manufacturer’s recommendations in accordance with API RP 1171, Section 9.3.2
(Section 9.3.2).
Section 9.3.2 states in part, “[s]urface and subsurface safety valve systems, where installed, shall
be function-tested at least annually. The tests shall be conducted in accordance with
manufacturer’s recommendations and the operator’s procedures.”
PHMSA reviewed ONEOK’s RSIMP, and found that Section 7.5.2.2 stated “[a]nnual function
testing of safety valve systems, surface and subsurface, and manually reopened at site after test”
but it did not include the procedures to be used to perform the tests or reference the manufacturer’s
recommendations.
Therefore, ONEOK’s written procedures required by § 192.12(c) were inadequate. ONEOK must
revise its procedure to address the deficiency outlined above.
4. § 192.12 Underground natural gas storage facilities.
(a) …
(d) Integrity management program--
(1) …
(4) Integrity management procedures and recordkeeping. Each
UNGSF operator must establish and follow written procedures to carry
out its integrity management program under API RP 1171
(incorporated by reference, see § 192.7), section 8 ("Risk Management
for Gas Storage Operations"), and this paragraph (d). The operator
must also maintain, for the useful life of the UNGSF, records that
12022043NOA_Notice of Amendment_04212022_(21-200378)_text Page 3 of 6



CPF 1-2022-043-NOA
demonstrate compliance with the requirements of this paragraph (d).
This includes records developed and used in support of any
identification, calculation, amendment, modification, justification,
deviation, and determination made, and any action taken to implement
and evaluate any integrity management program element.
ONEOK’s written procedures for carrying out its integrity management program were inadequate
to ensure safe operation of a pipeline facility. Specifically, ONEOK’s UNGS Risk Management
Plan (RMP), Section 4.6.2, Preventative and Mitigative Measures (Section 4.6.2) and Section
4.6.3, Methodology (Section 4.6.3) restated the language in API RP 1171 but did not include
details about the preventative and mitigative measures that were to be used to manage risk in
accordance with API RP 1171, Section 8.6.2, Methodology (Section 8.6.2).
Section 8.6.2 states in part, “[t]he operator shall develop P&M measures to manage risks.”
During the inspection, PHMSA reviewed ONEOK’s UNGS RMP, Section 4.6.2 and Section 4.6.3
and found that they restated the API RP 1171 language, and thus failed to include a process for
development of P&M measures needed to manage risk.
Therefore, ONEOK’s written procedures required by § 192.12(d)(4) were inadequate. ONEOK
must revise its procedure to address the deficiency outlined above.
5. § 192.12 Underground natural gas storage facilities.
(a) …
(d) Integrity management program--
(1) …
(4) Integrity management procedures and recordkeeping. Each
UNGSF operator must establish and follow written procedures to carry
out its integrity management program under API RP 1171
(incorporated by reference, see § 192.7), section 8 ("Risk Management
for Gas Storage Operations"), and this paragraph (d). The operator
must also maintain, for the useful life of the UNGSF, records that
demonstrate compliance with the requirements of this paragraph (d).
This includes records developed and used in support of any
identification, calculation, amendment, modification, justification,
deviation, and determination made, and any action taken to implement
and evaluate any integrity management program element.
ONEOK’s written procedures for carrying out its integrity management program were inadequate
to ensure safe operation of a pipeline facility. Specifically, ONEOK’s UNGS Risk Management
Plan (RMP), Section 4.3.2, Methodology, did not include a process to assess threat and hazard
interactions in accordance with API RP 1171, Section 8.3.2 (Section 8.3.2).
Section 8.3.2 states in part:
The operator shall use available information such as performance data collected through
the field history, operations and maintenance (O&M) activities, geotechnical data such as
12022043NOA_Notice of Amendment_04212022_(21-200378)_text Page 4 of 6



CPF 1-2022-043-NOA
6. well logs, engineering data, and completion reports to determine susceptibility to threat
and hazard-related events and to assess threat and hazard interaction.
PHMSA reviewed ONEOK’s RMP, and found that Section 4.3.2 stated “[O]NEOK will assess the
potential threat/hazard interaction, such as the relationship of the Threat of casing damage during
well drilling or service work that could exacerbate the corrosion process.” but it did not include a
process to assess interactions of threats and hazards specific to its UNGSFs.
Therefore, ONEOK’s written procedures required by § 192.12(d)(4) were inadequate. ONEOK
must revise its procedure to address the deficiency outlined above.
§ 192.12 Underground natural gas storage facilities.
(a) …
(d) Integrity management program--
(1) …
(4) Integrity management procedures and recordkeeping. Each
UNGSF operator must establish and follow written procedures to carry
out its integrity management program under API RP 1171
(incorporated by reference, see § 192.7), section 8 ("Risk Management
for Gas Storage Operations"), and this paragraph (d). The operator
must also maintain, for the useful life of the UNGSF, records that
demonstrate compliance with the requirements of this paragraph (d).
This includes records developed and used in support of any
identification, calculation, amendment, modification, justification,
deviation, and determination made, and any action taken to implement
and evaluate any integrity management program element.
ONEOK’s written procedures for carrying out its integrity management program were inadequate
to ensure safe operation of a pipeline facility. Specifically, ONEOK’s Reservoir Storage Integrity
Management Plan (RSIMP) did not include the timeline requirement for completing baseline risk
assessments in accordance with § 192.12(d)(2)1
.
During the inspection, PHMSA reviewed ONEOK’s RSIMP and found that it did not address the
baseline risk assessment timeline requirements outlined in § 192.12(d)(2).
1 § 192.12 Underground natural gas storage facilities.
(a) …
(d)
(1) …
(2) Integrity management baseline risk-assessment intervals.
No later than March 13, 2024, each UNGSF operator must complete the baseline risk assessments of all reservoirs
and caverns, and at least 40% of the baseline risk assessments for each of its UNGSF wells (including wellhead
assemblies), beginning with the highest-risk wells, as identified by the risk analysis process. No later than March 13,
2027, an operator must complete baseline risk assessments on all its wells (including wellhead assemblies).
Operators may use prior risk assessments for a well as a baseline (or part of the baseline) risk assessment in
implementing its initial integrity management program, so long as the prior assessments meet the requirements of
API RP 1171 (incorporated by reference, see §192.7), section 8, and continue to be relevant and valid for the current
operating and environmental conditions. When evaluating prior risk-assessment results, operators must account for
the growth and effects of indicated defects since the time the assessment was performed.
12022043NOA_Notice of Amendment_04212022_(21-200378)_text Page 5 of 6



CPF 1-2022-043-NOA
Therefore, ONEOK’s written procedures required by § 192.12(d)(4) were inadequate. ONEOK
must revise its procedure to address the deficiency outlined above.
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 Enforcement
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 30 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 Texas Gas Storage 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, 840 Bear Tavern Road,
Suite 300, West Trenton, NJ 08628. In correspondence concerning this matter, please refer to CPF
1-2022-043-NOA and, for each document you submit, please provide a copy in electronic format
whenever possible. Smaller files may be emailed to robert.burrough@dot.gov. Larger files should
be sent on USB flash drive accompanied by the original paper copy to the Eastern Region Office.
Sincerely,
Robert Burrough
Director, Eastern Region
Pipeline and Hazardous Materials Safety Administration
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings
12022043NOA_Notice of Amendment_04212022_(21-200378)_text Page 6 of 6
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