ONEOK NGL PIPELINE, LLC — Notice of Probable Violation

party submissionOfficial PDF320175005_Operator Response to Notice_06202017.pdf#

320175005_NOPV PCP PCO_05182017_text.pdf, page 1Official PDFNOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER CERTIFIED MAIL - RETURN RECEIPT REQUESTED May 15, 2017 Mr. Wes Christensen Senior Vice President of Operations ONEOK NGL Pipeline LP 100 West Fifth Street Tulsa, OK 74102 CPF 3-2017-5005 Dear Mr. Christensen: On various weeks between August 15, 2016 to December 16, 2016, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code, inspected ONEOK NGL Pipeline LP (ONEOK) records in Medford, Oklahoma, and Conway, Kansas for the facilities in Kansas and Nebraska. For the North System, facilities and records were inspected in Des Moines and Iowa City, Iowa. As a result of the investigation and the inspection, it appears that ONEOK has committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The probable violation(s) are: 1. §195.214 Welding procedures (a) Welding must be performed by a qualified welder or welding operator in accordance with welding procedures qualified under section 5, section 12,#

320175005_NOPV PCP PCO_05182017_text.pdf, page 22. Appendix A or Appendix B of API Std 1104 (incorporated by reference, see § 195.3), or Section IX of the ASME Boiler and Pressure Vessel Code (ASME BPVC) (incorporated by reference, see § 195.3). The quality of the test welds used to qualify the welding procedures must be determined by destructive testing. ONEOK did not qualify their welder to a welding procedure that was used to make a repair on an integrity management dig in 2013. While reviewing welder qualifications for a repair in November of 2013 on Line 11316, it was found that the repair welder was qualified to a procedure that was not used on the repair job. The welder was qualified to a procedure that uses a 6010 electrode in the root with a low-hydrogen electrode all the way out. However, the repair was made with a procedure which utilized low-hydrogen electrodes from the root out. The use of the low hydrogen rod on the root requires a change in welding direction, which is an essential variable according to API 1104 Section 6.3.2. The change requires the welder to be requalified to the new procedure. §195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. § 195.432 Inspection of In-Service Breakout Tanks (c) Each operator must inspect the physical integrity of in-service steel aboveground breakout tanks built to API Std 2510 (incorporated by reference, see §195.3) according to section 6 of API Std 510 (incorporated by reference, see §195.3). ONEOK did not have operation and maintenance procedures to address the requirements of API 510 for high-pressure tanks and the inspections that are necessary for these tanks. Review of ONEOK’s procedures noted that the procedures only addressed low pressure API 653 tanks and the associated inspections. ONEOK only operates tanks that fall under the inspection requirements of API 510. 2#

320175005_NOPV PCP PCO_05182017_text.pdf, page 33. 4. § 195.403 Emergency Response Training (b) At the intervals not exceeding 15 months, but at least once each calendar year, each operator shall: (1) Review with personnel their performance in meeting the objectives of the emergency response training program set forth in paragraph (a) of this section; At the Bushton facility, ONEOK did not review with personnel their performance in meeting the objectives of the emergency response training program at an interval not to exceed 15 months. ONEOK utilizes emergency response drills to train their personnel on the emergency response plans. After the drills, a post drill critique is done where ONEOK personnel review the results of the drill. While at the Bushton facilities, the records review noted that the 2014 response drill was conducted in June; and the following year, the drill was done on December 1, 2015. The dates of the drills exceeded the allowable 15 month interval. § 195.406 Maximum Operating Pressure (b) No operator may permit the pressure in a pipeline during surges or other variations from normal operations to exceed 110 percent of the operating pressure limit established under paragraph (a) of this section. Each operator must provide adequate controls and protective equipment to control the pressure within this limit. ONEOK did not provide adequate protective equipment to control the pressure within the maximum operating pressure at the Messena Pump Station. Review of the over pressure protection (OPP) records for the Messena Pump Station found that the OPP device was set higher than the maximum operating pressure (MOP) plus 10% from September 2014 until the time of the PHMSA inspection. The MOP of the line was 1,150 psig; the OPP device was set at 1300 psig. Review of the pressure charts found that the pipeline did not exceed the MOP anytime from 2014 until the PHMSA inspection. ONEOK indicated that they also had measures to protect the maximum operating pressure such as a shutdown programmed within the program logic controller (PLC). However, the inspections of this shutdown consisted only of a calibration check of the transmitter. There was no documentation or check of the shutdown showing that it operated at the proper set point during the inspection. 3#

320175005_NOPV PCP PCO_05182017_text.pdf, page 45. § 195.428 Overpressure Safety Devices and Overfill Protection Systems (a) Except as provided in paragraph (b) of this section, each operator shall, at intervals not exceeding 15 months, but at least once each calendar year, or in the case of pipelines used to carry highly volatile liquids, at intervals not to exceed 7½ months, but at least twice each calendar year, inspect and test each pressure limiting device, relief valve, pressure regulator, or other item of pressure control equipment to determine that it is functioning properly, is in good mechanical condition, and is adequate from the standpoint of capacity and reliability of operation for the service in which it is used. ONEOK did not inspect the OPP device for the Heartland Line twice a calendar year at intervals not to exceed 7½ months. Additionally, ONEOK did not inspect the pressure control valve (PCV) at the Iowa City Pump Station twice a year at intervals not to exceed 7½ months during 2014 and 2015. ONEOK typically utilizes a hard pressure switch at the pumps as their over pressure protection. On the Heartland Line in Des Moines, Iowa, there is no hard pressure switch. ONEOK indicated that they utilize a “soft-kill” within the PLC as the OPP device. Based on the records review, the only inspection documented for this OPP device was a pressure transmitter calibration check done bi-annually from 2014 to 2016. ONEOK later produced an inspection record of a full capacity relief located in the Heartland Terminal that is inspected by another operator. However, ONEOK had not been getting the inspection paperwork on that relief semi-annually from the owner/operator of that device. Regarding the PCV at the Iowa City Pump Station, it appears that the device was moved from the “semi-annual” inspection list to the “annual” inspection list in the fall of 2013. The valve was only inspected once per year in 2014 and 2015. In the fall of 2015, the valve was placed back on the “semi-annual” inspection list. 6. § 195.440 Public Awareness (d) The operator's program must specifically include provisions to educate the public, appropriate government organizations, and persons engaged in excavation related activities on: (2) Possible hazards associated with unintended releases from a hazardous liquid or carbon dioxide pipeline facility; ONEOK’s public education did not identify all the hazards associated with the products that they are transporting in their mailings to the public. 4#

320175005_NOPV PCP PCO_05182017_text.pdf, page 57. 8. On October 9, 2014, PHMSA issued a Warning Letter noting that ONEOK had failed to identify all the products that were being transported in the brochures sent out to the public. Specifically, refined products was left out of the mailings. During the records review in Des Moines, Iowa, it was found that the mailings that were being sent out still did not have refined products on the list nor did it indicate the hazards associated with the product. These mailings had not been updated since the 2014 Warning Letter. § 195.452 Pipeline Integrity Management in High Consequence Areas (l) What records must an operator keep to demonstrate compliance? (1) An operator must maintain, for the useful life of the pipeline, records that demonstrate compliance with the requirements of this subpart. At a minimum, an operator must maintain the following records for review during an inspection: (ii) Documents to support the decisions and analyses, including any modifications, justifications, deviations and determinations made, variances, and actions taken, to implement and evaluate each element of the integrity management program listed in paragraph (f) of this section. ONEOK is not documenting any preventive and mitigative measures that is taken for each line segment. Upon review of the preventive and mitigative measures (PMM), it was found that ONEOK was not documenting any additional measures that were being taken or that 195.452(i) includes. Actions taken such as implementing damage prevention best practices for the affected line segments, better monitoring of cathodic protection where corrosion is a concern, establishing shorter inspection intervals, installing EFRDs on the pipeline segment, modifying the systems that monitor pressure and detect leaks, providing additional training to personnel on response procedures, conducting drills with local emergency responders and adopting other management controls must be documented for each line segment. ONEOK maintained that additional measures were being done, but it did not appear to be reflected in the records for the line segments. § 195.579 What Must I do to Mitigate Internal Corrosion? (c) Removing pipe. Whenever you remove pipe from a pipeline, you must inspect the internal surface of the pipe for evidence of corrosion. If you find internal corrosion requiring corrective action under § 195.585, you must investigate circumferentially and longitudinally beyond the removed pipe (by visual examination, indirect method, or both) to determine whether additional corrosion requiring remedial action exists in the vicinity of the removed pipe. 5#

320175005_NOPV PCP PCO_05182017_text.pdf, page 6ONEOK did not inspect the internal surface of the pipe that was replaced on Line Segment 102. ONEOK records their pipe replacements on an “Equipment and Deletion” form. This form documents the internal inspection of the pipe when it is cut out. On Pipeline Segment 102, a 28-foot segment of the line was removed and replaced in July of 2013. The form for the 102 segment did not indicate that an internal inspection of the removed pipe was done for internal corrosion. ONEOK personnel investigated this and found that the inspection was missed because of a miscommunication in the field. Proposed Civil Penalty As of April 27, 2017, under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $209,002 per violation per day the violation persists up to a maximum of $2,090,022 for a related series of violations. The Compliance Officer has reviewed the circumstances and supporting documentation involved in the above probable violation(s) and has recommended that you be preliminarily assessed a civil penalty of $36,200 as follows: Item number PENALTY 6 $36,200 Warning Items With respect to items one (1), three (3), four (4), seven (7), and eight (8), we have reviewed the circumstances and supporting documents involved in this case and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to promptly correct these item(s). Failure to do so may result in additional enforcement action. Proposed Compliance Order With respect to items two (2) and five (5), pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to ONEOK NGL Pipeline, L.P. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Response to this Notice 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. All material you submit in response to this enforcement action may be 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 treatment6#

320175005_NOPV PCP PCO_05182017_text.pdf, page 7redacted 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, or request a hearing under 49 CFR § 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 a Final Order. If you are responding to this Notice, we propose that you submit your correspondence to my office within 30 days from receipt of this Notice. This period may be extended by written request for good cause. In your correspondence on this matter, please refer to CPF 3-2017-5005 and for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Allan C. Beshore Director, Central Region, OPS Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Compliance Proceedings 7#

320175005_NOPV PCP PCO_05182017_text.pdf, page 8PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to ONEOK NGL Pipeline, L.P. a Compliance Order incorporating the following remedial requirements to ensure the compliance of ONEOK NGL Pipeline, L.P (ONEOK) with the pipeline safety regulations: 1. 2. 3. In regard to Item Number 2 of the Notice pertaining to the lack of procedures for tanks designed to API 510, ONEOK shall complete the following:  Within 60 days following issuance of the Final Order, ONEOK must submit new procedures for operation and maintenance of the high pressure breakout tanks as required by API 510. In regard to Item Number 5 of the Notice pertaining to overpressure protection for the pipeline, ONEOK shall complete the following:  Submit an explanation to the Director, Central Region within 30 days following issuance of the Final Order outlining what ONEOK believes to be their overpressure protection for the Heartland pipeline and other similar pipeline facilities.  ONEOK should also include a plan to specify the inspection protocols for the various levels of overpressure protection, i.e. soft kills, hard kills.  Complete the revision of all relevant operating and maintenance procedures within 90 days following issuance of the Final Order. It is requested (not mandated) that ONEOK NGL Pipeline. L.P. maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Allan C. Beshore, Director, Central Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. 8#

320175005_Final Order_03292018_text.pdf, page 1Official PDFMarch 29, 2018 Mr. Terry K. Spencer President and CEO ONEOK Partners, LP 100 West Fifth Street Tulsa, OK 74102 Re: CPF No. 3-2017-5005 Dear Mr. Spencer: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation, assesses a civil penalty of $36,200, and specifies actions that need to be taken by ONEOK NGL Pipeline, LP, a subsidiary of ONEOK Partners, LP, to comply with the pipeline safety regulations. This is to acknowledge receipt of payment of the full penalty amount, by wire transfer, dated June 21, 2017. When the terms of the compliance order are completed, as determined by the Director, Central Region, this enforcement action will be closed. Service of the Final Order by certified mail is effective upon the date of mailing as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure cc: Mr. Allan C. Beshore, Director, Central Region, Office of Pipeline Safety, PHMSA CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

320175005_Final Order_03292018_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ In the Matter of ) ONEOK NGL Pipeline, LP, ) CPF No. 3-2017-5005 a subsidiary of ONEOK Partners, LP, ) ) ) ) Respondent. ) ____________________________________) FINAL ORDER On multiple occasions between August 15, 2016, and December 16, 2016, pursuant to 49 U.S.C. § 60117, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), conducted an on-site pipeline safety inspection of the facilities and records of ONEOK NGL Pipeline, LP (ONEOK or Respondent), in Medford, Oklahoma, and Conway, Kansas, for the facilities in Kansas and Nebraska. ONEOK operates approximately 2,440 miles of FERC-regulated natural gas liquids (NGL) pipelines, with a peak capacity of 393,000 barrels per day. Its NGL gathering pipelines deliver NGLs gathered in Oklahoma, Kansas, and the Texas Panhandle to separate fractionation facilities.1 As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent, by letter dated May 18, 2017, a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice), which also included a warning pursuant to 49 C.F.R. § 190.205. In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that ONEOK had violated three sections of 49 C.F.R. Part 195 and proposed assessing a civil penalty of $36,200 for one of the alleged violations. The Notice also proposed ordering Respondent to take certain measures to correct the alleged violations. The warning items required no further action, but warned the operator to correct the probable violations or face possible future enforcement action. ONEOK responded to the Notice by letter dated June 20, 2017 (Response). The company did not contest the allegations of violation, agreed to complete the proposed compliance actions, and paid the civil penalty in full by wire transfer dated June 21, 2017. Respondent did not request a hearing and therefore has waived its right to one. 1 See https://www.oneok.com/en/partners/Customers/NaturalGasLiquids/Pipelines/NGLPipeline. (Current as of 10/16/2017)#

320175005_Final Order_03292018_text.pdf, page 3CPF No. 3-2017-5005 Page 2 FINDINGS OF VIOLATION In its Response, ONEOK did not contest the allegations in the Notice that it violated 49 C.F.R. Part 195, as follows: Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), which states: § 195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) by failing to prepare written procedures for conducting certain operation and maintenance activities. Specifically, the Notice alleged that Respondent failed to have operation and maintenance procedures for breakout tanks that meet the requirements of API 510 for high-pressure tanks and the inspections that are necessary for these tanks.2 The Notice alleged that ONEOK’s procedures only address low- pressure API 653 tanks and the associated inspections, but that ONEOK only operates tanks that fall under the inspection requirements of API 510. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.402(a) by failing to have procedures for conducting operation and maintenance activities for breakout tanks that meet the requirements of API 510 for high-pressure tanks and the inspections that are necessary for those tanks. Item 5: The Notice alleged that Respondent violated 49 C.F.R. § 195.428(a), which states: § 195.428 Overpressure safety devices and overfill protection systems. (a) Except as provided in paragraph (b) of this section, each operator shall, at intervals not exceeding 15 months, but at least once each calendar year, or in the case of pipelines used to carry highly volatile liquids, at intervals not to exceed 7½ months, but at least twice each calendar year, inspect and test each pressure limiting device, relief valve, pressure regulator, or other item of pressure control equipment to determine that it is functioning properly, is in good mechanical condition, and is adequate from 2 The Notice also referenced 49 C.F.R. § 195.432(c), which requires operators to inspect the physical integrity of in- service steel aboveground breakout tanks built to API Std 2510 according to section 6 of API Std 510 (both incorporated by reference, see §195.3).#

320175005_Final Order_03292018_text.pdf, page 4CPF No. 3-2017-5005 Page 3 the standpoint of capacity and reliability of operation for the service in which it is used. The Notice alleged that Respondent violated 49 C.F.R. § 195.428(a) by failing to inspect each pressure limiting device or other pressure control equipment on a pipeline used to carry highly volatile liquids, at intervals not to exceed 7½ months, but at least twice each calendar year to determine that it is functioning properly, is in good mechanical condition, and is adequate from the standpoint of capacity and reliability for the service in which it is used. Specifically, the Notice alleged that Respondent failed to inspect the overpressure protection (OPP) device for the Heartland Line or the Iowa City Pump Station twice each calendar year at intervals not to exceed 7½ months. The Notice alleged that based on a records review of the Heartland Line, the only documented inspection of the “soft-kill” OPP device was a pressure-calibration check done bi- annually from 2014 to 2016. ONEOK later produced an inspection record of a full capacity relief in the Heartland Terminal (inspected by another operator), but that paperwork was not received by Respondent semi-annually. In terms of the Iowa City Pump Station, the OPP device was moved from the “semi-annual” to the “annual” inspection list in the fall of 2013. The valve was subsequently placed on the “semi-annual” list again in 2015. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.428(a) by failing to inspect the OPP device for the Heartland Line or the Iowa City Pump Station twice each calendar year, at intervals not to exceed 7½ months. Item 6: The Notice alleged that Respondent violated 49 C.F.R. § 195.440(d)(2), which states: § 195.440 Public awareness. (a) Each pipeline operator must develop and implement a written continuing public education program that follows the guidance provided in the American Petroleum Institute's (API) Recommended Practice (RP) 1162 (incorporated by reference, see § 195.3). . . (d) The operator’s program must specifically include provisions to educate the public, appropriate government organizations, and persons engaged in excavation related activities on: (1) … (2) Possible hazards associated with unintended releases from a hazardous liquid or carbon dioxide pipeline facility; . . . . The Notice alleged that Respondent violated 49 C.F.R. § 195.440(d)(2) by failing to include provisions in its public education program to educate the public on all the hazards associated with unintended releases of the products that ONEOK transports. Specifically, the Notice alleged that even though PHMSA issued an October 2014 Warning Letter to ONEOK, alerting the company to the fact that it had failed to identify all the products being transported in its public awareness brochure, a subsequent records review showed that Respondent’s public awareness mailings still did not have refined products on the list of transported goods nor did they indicate the hazards associated with transporting refined products.#

320175005_Final Order_03292018_text.pdf, page 5CPF No. 3-2017-5005 Page 4 Respondent did not contest this allegation of violation. Accordingly, based upon a review of all of the evidence, I find that Respondent violated 49 C.F.R. § 195.440(d)(2) by failing to identify in its public-awareness mailings all the hazards associated with the products that ONEOK transports. These findings of violation will be considered prior offenses in any subsequent enforcement action taken against Respondent. ASSESSMENT OF PENALTY Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed $200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any related series of violations.3 In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature, circumstances, and gravity of the violation, including adverse impact on the environment; the degree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect that the penalty may have on its ability to continue doing business; and the good faith of Respondent in attempting to comply with the pipeline safety regulations. In addition, I may consider the economic benefit gained from the violation without any reduction because of subsequent damages, and such other matters as justice may require. The Notice proposed a total civil penalty of $36,200 for the violation of § 195.440(d)(2) in Item 6 cited above. Item 6: The Notice proposed a civil penalty of $36,200 for Respondent’s violation of 49 C.F.R. § 195.440(d)(2), for failing to identify in its public-awareness mailings all the hazards associated with the products ONEOK transports. ONEOK neither contested the allegation nor presented any evidence or argument justifying either a reduction of or elimination of the proposed penalty. Even though OPS alleged that pipeline safety was minimally affected, ONEOK failed to comply with a clearly applicable requirement after it was brought to the company’s attention by a Warning Letter in 2014. In addition, ONEOK failed to carry out its public-awareness program without any reasonable justification. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $36,200 for violation of 49 C.F.R. § 195.440(d)(2). In summary, having reviewed the record and considered the assessment criteria for each of the Items cited above, I assess Respondent a total civil penalty of $36,200. By wire transfer dated June 21, 2017, ONEOK has paid the penalty amount in full. No further penalty assessment is needed at this time. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Items 2 and 5 in the Notice for 3 These amounts are adjusted annually for inflation. See, e.g., Pipeline Safety: Inflation Adjustment of Maximum Civil Penalties, 82 Fed. Reg. 19325 (April 27, 2017).#

320175005_Final Order_03292018_text.pdf, page 6CPF No. 3-2017-5005 Page 5 violations of 49 C.F.R. §§ 195.402(a) and 195.428(a), respectively. Under 49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217, Respondent is ordered to take the following actions to ensure compliance with the pipeline safety regulations applicable to its operations: 1. With respect to the violation of § 195.402(a) (Item 2), Respondent shall complete the following: a. Within 60 days following issuance of this Final Order, ONEOK must submit new procedures for operation and maintenance of the high-pressure breakout tanks, as required by API 510. 2. With respect to the violation of § 195.428(a) (Item 5), Respondent shall complete the following: a. Submit a written explanation to the Director, Central Region, within 30 days following issuance of this Final Order, outlining what ONEOK believes to be its overpressure protection for the Heartland Pipeline and other similar pipeline facilities; b. ONEOK must submit a written plan to specify the inspection protocols for the various levels of overpressure protection, i.e. soft kills, hard kills; c. ONEOK must complete the revision of all relevant operating and maintenance procedures within 90 days following issuance of this Final Order. 3. It is requested (not mandated) that ONEOK maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Allan C. Beshore, Director, Central Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses; and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. Failure to comply with this Order may result in the administrative assessment of civil penalties not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), for each violation for each day the violation continues or in referral to the Attorney General for appropriate relief in a district court of the United States.#

320175005_Final Order_03292018_text.pdf, page 7CPF No. 3-2017-5005 Page 6 WARNING ITEMS With respect to Items 1, 3, 4, 7 and 8, the Notice alleged probable violations of Part 195 but did not propose a civil penalty or compliance order for these items. Therefore, these are considered to be warning items. The warnings were for: 49 C.F.R. § 195.214(a) (Item 1) ─ Respondent’s alleged failure to qualify one of its welders to a welding procedure used to make a repair on an integrity management dig in 2013; 49 C.F.R. § 195.403(b)(1) (Item 3) ─ Respondent’s alleged failure to review with personnel their performance in order to meet the objectives of ONEOK’s emergency-response training program, at intervals not to exceed 15 months; 49 C.F.R. § 195.406(b) (Item 4) ─ Respondent’s alleged failure to provide adequate protective equipment to control the pressure within the maximum operating pressure of the pipeline at the Messena Pump Station; 49 C.F.R. § 195.452(l)(1)(ii) (Item 7) ─ Respondent’s alleged failure to document any preventive or mitigative measures taken under its integrity management program for each line segment; and 49 C.F.R. § 195.579(c) (Item 8) ─ Respondent’s alleged failure to inspect the internal surface of the pipe section that was replaced on Line Segment 102. If OPS finds a violation of any of these items in a subsequent inspection, Respondent may be subject to future enforcement action. The terms and conditions of this Final Order are effective upon service in accordance with 49 C.F.R. § 190.5. March 29, 2018 ___________________________________ __________________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

320175005_Closure Letter_03302018_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED March 30, 2018 Mr. Wes Christensen Senior Vice President of Operations ONEOK NGL Pipeline LP 100 West Fifth Street Tulsa, OK 74102 CPF 3-2017-5005 Dear Mr. Christensen: On March 29, 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to ONEOK NGL Pipeline LP a Final Order in the above-referenced case. This Order included a Compliance Order and Civil Penalty assessment. Based on our review of the documentation you provided on December 8, 2017 and January 17, 2018 and confirmation of payment of the civil penalty, it has been determined that you have complied with the terms of this Order. Accordingly, this case is now closed and no further action is contemplated with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Allan C. Beshore Director, OPS, Central Region Pipeline and Hazardous Materials Safety Administration#