MAGELLAN PIPELINE COMPANY, LP — Notice of Probable Violation

party submissionOfficial PDF32023022NOPV_Operator Withdrawal of Hearing Request_01262024_(22-234357).pdf#

case documentOfficial PDF32023022NOPV_PCP PCO_08242023_(22-234357).pdf#

case documentOfficial PDF32023022NOPV_PCP PCO_08242023_(22-234357)_text.pdf#

32023022NOPV_Consent Agreement and Order_01222024_(22-234357)_text.pdf, page 1Official PDFJanuary 22, 2024 VIA ELECTRONIC MAIL TO: Pierce.Norton@oneok.com Pierce H. Norton II President and Chief Executive Officer ONEOK, Inc. 100 West Fifth Street Tulsa, Oklahoma 74103 CPF No. 3-2023-022-NOPV Dear Mr. Norton: Enclosed please find a Consent Order incorporating the terms of the Consent Agreement between the Pipeline and Hazardous Materials Safety Administration (PHMSA) and Magellan Midstream Partners, LP which was executed on January 16, 2024. Service of the Consent Order and Consent Agreement by electronic mail is deemed effective upon the date of transmission and acknowledgement of receipt, or as otherwise 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 Enclosures: Consent Order and Consent Agreement cc: Mr. Gregory A. Ochs, Director, Central Region, Office of Pipeline Safety, PHMSA Mr. Danny Scroggins, Senior Attorney, ONEOK, Danny.Scroggins@oneok.com Mr. Mark Materna, Director, Pipeline Integrity, ONEOK, Mark.Materna@oneok.com CONFIRMATION OF RECEIPT REQUESTED#

32023022NOPV_Consent Agreement and Order_01222024_(22-234357)_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 ) MAGELLAN MIDSTREAM ) PARTNERS, LP, ) CPF No. 3-2023-022-NOPV ) ) ) Respondent. ) ____________________________________) CONSENT ORDER By letter dated August 24, 2023, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), issued a Notice of Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order (Notice) to Magellan Midstream Partners, LP (Magellan or Respondent). On September 25, 2023, Magellan was acquired by ONEOK, Inc. In response to the Notice, Respondent contested the allegation of violation, proposed civil penalty, and proposed compliance order term for Item 5, and the proposed civil penalty for Item 6. Magellan requested a hearing and the opportunity to meet informally with PHMSA to discuss Items 5 and 6 in the Notice. Respondent and PHMSA (the Parties) subsequently met to discuss the issues raised in the Response. As a result of those discussions, as explained in more detail below, the Parties have agreed to a Consent Agreement by which PHMSA makes findings of violation for Items 1, 2, 4, and 6, assesses a reduced civil penalty of $150,700, withdraws Item 5, and sets out certain corrective actions that Magellan will complete. Accordingly, the Consent Agreement is hereby approved and incorporated by reference into this Consent Order. Magellan is hereby ordered to comply with the terms of the Consent Agreement pursuant to its terms. Pursuant to 49 U.S.C. § 60101, et seq., failure to comply with this Consent Order may result in the assessment of civil penalties as set forth in 49 U.S.C. § 60122 and 49 C.F.R. § 190.223, or in referral to the Attorney General for appropriate relief in a district court of the United States. The terms and conditions of this Consent Order are effective upon service in accordance with 49 C.F.R. § 190.5. January 22, 2024 ______________________________ ______________________ Alan K. Mayberry Date Issued Associate Administrator for Pipeline Safety#

32023022NOPV_Consent Agreement and Order_01222024_(22-234357)_text.pdf, page 3U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ ) In the Matter of ) ) MAGELLAN MIDSTREAM ) PARTNERS, LP, ) CPF No. 3-2023-022-NOPV ) Respondent. ) ____________________________________) CONSENT AGREEMENT From February 7, 2022 through October 14, 2022, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted an on-site inspection of Magellan Midstream Partners LP’s (Magellan or Respondent) Central, North, and Razorback system records and facilities in Arkansas, Illinois, Kansas, Minnesota, Missouri, Nebraska, North Dakota, Oklahoma, South Dakota, and Wisconsin. As of September 25, 2023, Magellan was acquired by ONEOK, Inc. As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent, by letter dated August 24, 2023, a Notice of Probable Violation, Proposed Compliance Order, and Proposed Civil Penalty (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that Magellan committed violations of six provisions of 49 C.F.R. part 195, proposed ordering Respondent to take certain measures to correct the alleged violations, and proposed a civil penalty of $219,500. Item 3 was brought as a warning, advising the operator to correct the probable violation or face potential future enforcement action. Magellan responded to the Notice by letter dated September 22, 2023 (Response). The company contested the violation, the proposed civil penalty, and the proposed compliance order for Item 5, and the proposed civil penalty for Item 6. Magellan requested an informal meeting with PHMSA to discuss both Items 5 and 6 and requested a hearing on these Items. PHMSA and Respondent (the Parties) subsequently met to discuss the issues raised in the Response. As a result of those discussions and as explained in more detail below, the Parties have agreed to a Consent Agreement by which PHMSA makes findings of violations for Items 1, 2, 4, and 6, assesses a reduced civil penalty of $150,700, withdraws Item 5, and sets out certain corrective actions that Magellan will complete.#

32023022NOPV_Consent Agreement and Order_01222024_(22-234357)_text.pdf, page 4Having agreed that settlement of this proceeding will avoid further administrative proceedings or litigation and will serve the public interest by promoting safety and protection of the environment, pursuant to 49 U.S.C. § 60101, et seq. and 49 C.F.R. Part 190, and upon consent and agreement, the Parties hereby agree as follows: I. General Provisions 1. Respondent acknowledges that as the operator of the pipeline facilities subject to the Notice, Respondent and its referenced pipeline facilities are subject to the jurisdiction of the Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and administrative orders issued thereunder. For purposes of this Consent Agreement (Agreement), Respondent acknowledges that it received proper notice of PHMSA’s action in this proceeding and that the Notice states claims upon which relief may be granted pursuant to 49 U.S.C. § 60101, et seq., and the regulations and orders issued thereunder. 2. After Respondent returns this signed Agreement to PHMSA, the Agency’s representative will present it to the Associate Administrator for Pipeline Safety, recommending that the Associate Administrator adopt the terms of this Agreement by issuing an administrative order (Consent Order) incorporating the terms of this Agreement. The terms of this Agreement constitute an offer of settlement until accepted by the Associate Administrator. Once accepted, the Associate Administrator will issue a Consent Order incorporating the terms of this Agreement. 3. Respondent consents to the issuance of the Consent Order, and hereby waives any further procedural requirements with respect to its issuance. Respondent waives all rights to contest the adequacy of notice, or the validity of the Consent Order or this Agreement, including all rights to administrative or judicial hearings or appeals, except for the Dispute Resolution provisions set forth herein. Respondent agrees to withdraw its request for an administrative hearing regarding the Notice. 4. This Agreement shall apply to and be binding upon PHMSA and Respondent, its officers, directors, and employees, and its successors, assigns, or other entities or persons otherwise bound by law. Respondent agrees to provide a copy of this Agreement and any incorporated work plans and schedules to all of Respondent’s officers, employees, and agents whose duties might reasonably include compliance with this Agreement. 5. This Agreement constitutes the final, complete, and exclusive agreement and understanding between the Parties with respect to the settlement embodied in this Agreement. The Parties acknowledge that there are no representations, agreements or understandings relating to settlement other than those expressly contained in this Agreement, except that the terms of this Agreement may be construed by reference to the Notice. 6. Nothing in this Agreement affects or relieves Respondent of its responsibility to comply with all applicable requirements of the Federal pipeline safety laws, 49 U.S.C. § 60101, et seq., and the regulations and orders issued thereunder. Nothing in this Agreement alters PHMSA's right of access, entry, inspection, and information gathering or PHMSA's authority to bring#

32023022NOPV_Consent Agreement and Order_01222024_(22-234357)_text.pdf, page 5enforcement actions against Respondent pursuant to the Federal pipeline safety laws, the regulations and orders issued thereunder, or any other provision of Federal or State law. 7. For all transfers of ownership or operating responsibility of Respondent’s pipeline system referenced herein, Respondent will provide a copy of this Agreement to the prospective transferee at least 30 days prior to such transfer. Respondent will provide written notice of the transfer to the Director no later than 60 days after the transfer occurs. 8. This Agreement does not waive or modify any Federal, State, or local laws or regulations that are applicable to Respondent’s pipeline systems. This Agreement is not a permit, or a modification of any permit, under any Federal, State, or local laws or regulations. Respondent remains responsible for achieving and maintaining compliance with all applicable Federal, State, and local laws, regulations and permits. 9. This Agreement does not create rights in, or grant any cause of action to, any third party not party to this Agreement. The U.S. Department of Transportation is not liable for any injuries or damages to persons or property arising from acts or omissions of Respondent or its officers, employees, or agents carrying out the work required by this Agreement. Respondent agrees to hold harmless the U.S. Department of Transportation, its officers, employees, agents, and representatives from any and all causes of action arising from any acts or omissions of Respondent or its contractors in carrying out any work required by this Agreement. 10. Except as set forth herein, this Agreement does not constitute a finding of violation of any other federal law or regulation and may not be used in any civil proceeding of any kind as evidence or proof of any fact, fault, or liability, or as evidence of a violation of any law, rule, regulation, or requirement, except in a proceeding to enforce the provisions of this Agreement or in future PHMSA enforcement actions. II. Findings of Violation: 11. Item 1- 49 C.F.R. § 195.264(b)(1)(i): The Notice alleged that Magellan failed to satisfy the requirements of Section 22.11.2 of NFPA-30 (2012 ed.) regarding impoundment around breakout tanks. Specifically, the Notice alleged that PHMSA’s field inspection of Magellan tanks 1516, 1517, 1521, and 3502 at the Kansas City East Tank Farm in Kansas City, Kansas, found that Magellan failed to subdivide the tanks, and failed to have drainage channels or intermediate dikes installed in accordance with the referenced standard and the regulation. Respondent does not contest the allegation of violation as alleged in the Notice. As such, PHMSA finds a violation of 49 C.F.R. § 195.264(b)(1)(i). 12. Item 2- 49 C.F.R. § 195.402(a): The Notice alleged that Magellan failed to follow procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. Specifically, the Notice alleged that Magellan failed to take corrective action where deficiencies were found during abnormal operations. Respondent does not contest the allegation of violation as alleged in the Notice. As such, PHMSA finds a violation of 49 C.F.R. § 195.402(a).#

32023022NOPV_Consent Agreement and Order_01222024_(22-234357)_text.pdf, page 613. Item 4- 49 C.F.R. § 195.404(c)(3): The Notice alleged that Magellan failed to maintain a record of each inspection and test required for at least two years or until the next inspection or test is performed. Specifically, the Notice alleged that Magellan failed to maintain eight records for Tank 408 in Nebraska City, Nebraska, from April of 2021 and January through July of 2022. Respondent does not contest the allegation of violation as alleged in the Notice. As such, PHMSA finds a violation of 49 C.F.R. § 195.404(c)(3). 14. Item 6- 49 C.F.R. § 195.428(a): The Notice alleged that Magellan failed to inspect and test two devices at its Roland, Iowa facility for calendar year 2020. Specifically, the Notice alleged that during the field inspection and records review of Roland, Iowa, facility, PHMSA found that two devices, thermal relief MLBV 64 and thermal relief MLBV 65, were not inspected and tested. Respondent does not contest the allegation of violation as alleged in the Notice. As such, PHMSA finds a violation of 49 C.F.R. § 195.428(a). 15. Items 1, 2, 4 and 6, will be considered by PHMSA as prior offenses in any future PHMSA enforcement action taken against Respondent for the five (5)-year period following the Effective Date of this Agreement. III. Warning Item: 16. Item 3- 49 C.F.R. § 195.402(a): The Notice alleged that Magellan failed to follow procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. Specifically, the Notice alleged that during the field inspection and records review at Fargo, North Dakota, PHMSA found that five devices were not properly documented as required by the procedure. This Item was brought as a Warning Item and does not constitute a finding of violation. Respondent accepts the warning as alleged in the Notice. 17. For Warning Item 3, if OPS finds a violation of these provisions in a subsequent inspection, Respondent may be subject to future enforcement action. IV. Items Withdrawn: 18. Item 5- 49 C.F.R. § 195.412(a): With respect to Item 5 of the Notice, the Parties agree that this Item should be withdrawn in its entirety following review of Magellan’s Response, which included Magellan’s 7.05-ADM-006 Inspection of Right-of-Way Procedure and 2022 seasonal Ground Patrol records. These documents show that Respondent was not out of compliance with the regulation. Because this Item will be withdrawn, it will not constitute a finding of violation for any purpose, and no further action by Respondent is necessary to achieve compliance. As such, the allegation of violation for Item 5, the proposed civil penalty associated with this Item, and the proposed compliance order associated with this Item are withdrawn. V. Civil Penalty: 19. Item 4: The Notice proposed assessing a civil penalty in the amount of $65,100. Respondent did not contest the proposed civil penalty for this Item. As such, Respondent shall pay a civil penalty in the amount of $65,100 for Item 4.#

32023022NOPV_Consent Agreement and Order_01222024_(22-234357)_text.pdf, page 720. Item 5: The Notice proposed assessing a civil penalty in the amount of $68,800 for Item 5. Respondent contested the proposed civil penalty for this Item. Following discussions with Respondent, PHMSA determined that Magellan was not out of compliance with the regulation and this proposed civil penalty was withdrawn. 21. Item 6: The Notice proposed assessing a civil penalty in the amount of $85,600 for Item 6. Following discussion with PHMSA, Respondent agrees to pay a civil penalty in the amount of $85,600 for the violation in Item 6. 22. In total, based on Paragraphs 19-21, Respondent shall pay an adjusted civil penalty in the amount of $150,700, pursuant to the payment instructions at 49 C.F.R. § 190.227(a), to be paid in full no later than 20 days from the Effective Date of this Agreement. VI. Compliance Order: 23. Item 1: The Notice proposed certain compliance order actions to address the non- compliance alleged in the Notice. Respondent did not contest the Proposed Compliance Order. As such, Respondent agrees to perform the following corrective measures: A. In regard to Item 1 of the Notice pertaining to Magellan’s failure to satisfy the requirements of Section 22.11.2 of NFPA-30 (2012 edition) regarding the impoundment around breakout tanks, Magellan must: (i) Subdivide the tanks preferably by drainage channels or at least by intermediate dikes, in accordance with NFPA 30 at the Kansas City East Terminal within twelve (12) months of receipt of the Consent Order. (ii) Submit to the Director, Central Region, evidence of remediated locations to demonstrate compliance with NFPA 30. 24. Item 2: The Notice proposed certain compliance order actions to address the non- compliance alleged in the Notice. Respondent did not contest the Proposed Compliance Order. As such, Respondent agrees to perform the following corrective measures: B. In regard to Item 2 of the Notice pertaining to Magellan’s failure to take corrective action on two documented abnormal operations (AO), Magellan must amend its procedures to incorporate timeframe requirements for the review, corrective action, and documentation of AOs to ensure timely corrective action is completed where deficiencies are found. The revised procedures shall be submitted to the Director, PHMSA Central Region for review and approval within 60 days of receipt of the Consent Order. It is requested that Magellan Midstream Partners, LP maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Gregory A. Ochs, Director, Central Region, OPS, 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 C.#

32023022NOPV_Consent Agreement and Order_01222024_(22-234357)_text.pdf, page 8plans, procedures, studies and analyses, and (2) total cost associated with replacements, additions and other changes to pipeline infrastructure.1 VII. Enforcement: 25. This Agreement is subject to all enforcement authorities available to PHMSA under 49 U.S.C. § 60101, et seq., and 49 C.F.R. Part 190, including administrative civil penalties under 49 U.S.C. § 60122, of up to $257,664 per violation for each day the violation continues and referral of the case to the Attorney General for judicial enforcement, if PHMSA determines that Respondent is not complying with the terms of this Agreement in accordance with the determinations made by the Director, or in accordance with decisions of the Associate Administrator if resolved pursuant to the Dispute Resolution process herein. The maximum civil penalty amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223. All work plans and associated schedules set forth or referenced in Section VI are automatically incorporated into this Agreement and are enforceable in the same manner. VIII. Review and Approval Process: 26. With respect to any submission under Section VI (Compliance Order) of this Agreement that requires the approval of the Director, the Director may: (a) approve, in whole or in part, the submission; (b) approve the submission on specified, reasonable conditions; (c) disapprove, in whole or in part, the submission; or (d) any combination of the foregoing. If the Director approves, approves in part, or approves with conditions, Respondent will take all actions as approved by the Director, subject to Respondent’s right to invoke the dispute resolution procedures with respect to any conditions the Director identifies. If the Director disapproves all or any portion of the submission, the Director will provide Respondent a written notice of the deficiencies. Respondent will correct all deficiencies within the time specified by the Director and resubmit it for approval. IX. Dispute Resolution: 27. The Director and Respondent will informally attempt to resolve any disputes arising under this Agreement, including any decision of the Director under the terms of Section VI, Compliance Order. If Respondent and the Director are unable to informally resolve the dispute within 15 calendar days after the dispute is first raised, in writing, to the Director, Respondent may submit a written request for a determination resolving the dispute from the Associate Administrator for Pipeline Safety, PHMSA. Such request must be made in writing and provided to the Director, counsel for the Central Region, and to the Associate Administrator for Pipeline Safety, no later than 10 calendar days from the 15-day deadline for informal resolution referenced in this paragraph. Along with its request, Respondent must provide the Associate Administrator with all information Respondent believes is relevant to the dispute. Decisions of the Associate Administrator under this paragraph will constitute final agency action. The existence of a dispute and PHMSA’s consideration of matters placed in dispute will not excuse, toll, or suspend any term or timeframe for completion of any work to be performed under this Agreement during the pendency of the dispute resolution process. 1 This Proposed Compliance Order term was originally term D in the Notice.#

32023022NOPV_Consent Agreement and Order_01222024_(22-234357)_text.pdf, page 9X. Effective Date: 28. The term “Effective Date,” as used herein, is the date on which the Consent Order is issued by the Associate Administrator, PHMSA, incorporating the terms of this Agreement. XI. Recordkeeping and Information Disclosure: 29. Unless otherwise required in this Agreement, Respondent agrees to maintain records demonstrating compliance with all requirements of this Agreement for a period of at least five (5) years following completion of all work to be performed. For any reports, plans, or other deliverables required to be submitted to PHMSA pursuant to this Agreement, Respondent may assert a claim of business confidentiality or other protections applicable to the release of information by PHMSA, covering part or all of the information required to be submitted to PHMSA pursuant to this Agreement in accordance with 49 C.F.R. Part 7. Respondent must mark the claim of confidentiality in writing on each page and include a statement specifying the grounds for each claim of confidentially. PHMSA determines release of any information submitted pursuant to this Agreement in accordance with 49 C.F.R. Part 7, the Freedom of Information Act, 5 U.S.C. § 552, DOT and PHMSA policies, and other applicable regulations and Executive Orders. XII. Modification: 30. The terms of this Agreement may be modified by mutual agreement of the Parties. Such modifications must be in writing and signed by both parties. XIII. Termination: 31. This Agreement will remain in effect until the Compliance Order in Section VI is satisfied, as determined by the Director, and payment of the Civil Penalty in Section V is made. The Agreement shall not terminate until the Director confirms, in writing, that the Agreement is terminated in accordance with this paragraph. Nothing in this Agreement prevents Respondent from completing any of the obligations earlier than the deadlines provided for in this Agreement. XIV. Ratification: 32. The Parties’ undersigned representatives certify that they are fully authorized to enter into the terms and conditions of this Agreement and to execute and legally bind such party to this document. 33. The Parties hereby agree to all findings, conditions, and terms of this Agreement. [Signature Lines on Following Page]#

32023022NOPV_Consent Agreement and Order_01222024_(22-234357)_text.pdf, page 10For MAGELLAN MIDSTREAM PARTNERS, LP: _________________________ Jason A. Smith, Vice President of Asset Integrity ________________________ Date For PHMSA: ________________________________________ Director, Central Region, Office of Pipeline Safety ________________________ Date#

32023022NOPV_Op Resp to Notice and Req for Hearing_09222023_(22-234357).pdf, page 1Official PDFOne Williams Center PO BOX 22186 Tulsa, OK 74172-2186 September 22, 2023 Via Electronic Mail to: Gregory.Ochs@dot.gov Mr. Gregory A. Ochs, Director Central Region, Pipeline and Hazardous Materials Safety Administration 901 Locust Street, Suite 480 Kansas City, MO 64106 Re: CPF 3-2023-022 Dear Mr. Ochs, Magellan Pipeline Company, L.P. (“Magellan”) received a Notice of Probable Violation (NOPV), Proposed Civil Penalties and Proposed Compliance Order, CPF 3-2023-022, on August 24, 2023. Pursuant to 49 CFR 190.209, Magellan requested a copy of the Case File to review the basis for the allegations and a copy of the Proposed Civil Penalty Worksheet on August 29, 2023 which PHMSA provided on September 1, 2023. Magellan respectfully submits the following response in accordance with the Response Options for Pipeline Operators in Enforcement Proceedings. Magellan contests the probable violation, proposed Civil Penalty and proposed Compliance Order for Item #5 as explained in this response. Magellan does not contest the basis for the remaining items, but does contest the Civil Penalty Calculation for Item #6. Magellan requests a hearing on this matter and also requests an informal settlement conference as it believes that this matter can be fully resolved prior to a hearing. Item #5: § 195.412 Inspection of rights-of-way and crossings under navigable waters. (a) Each operator shall, at intervals not exceeding 3 weeks, but at least 26 times each calendar year, inspect the surface conditions on or adjacent to each pipeline right-of-way. Methods of inspection include walking, driving, flying or other appropriate means of traversing the right-of-way. Magellan failed to inspect the surface conditions on or adjacent to each pipeline right-of-way (ROW) with an acceptable method. Specifically, Magellan did not maintain the pipeline right-of-way conditions at a level that allowed for effective aerial inspection of the surface conditions on or adjacent to the ROW and did not select an alternate patrol method that would allow effective inspection based on the condition of the ROW. PHMSA’s onsite inspection discovered excessive vegetation cover over#

32023022NOPV_Op Resp to Notice and Req for Hearing_09222023_(22-234357).pdf, page 2the ROW in Grand Forks, North Dakota near 34th street and Desert Star Lane. This location had been aerially patrolled, however, no deficiencies in the ROW condition were called out by the patrol. MAGELLAN RESPONSE: Magellan contests Item #5, the associated Proposed Compliance Order and the Proposed Civil Penalty associated with this item. Magellan had been performing ground patrols of the area near 34th Street and Desert Star Lane prior to the 2022 inspection and has associated documentation of ground patrols of this area. Magellan aerial patrols this line year-round in addition to performing supplemental ground patrols seasonally due to tree foliage (typically June through October) from MP 177 to MP 179 (which includes the 34th Street and Desert Star Lane area). No deficiencies indicative of a potential release were identified on the ROW during these patrols. Please see Attachment #1 – Ground Patrols with the 2022 seasonal ground patrol records. In addition to completing seasonal ground patrols for the area noted, Magellan has a procedure detailing the requirement for aerial patrol pilots to document vegetation overgrowth and deficiencies in the ROW condition. Please see Attachment #2, 7.05- ADM-006 Inspection of Right-of-Way Procedure. Magellan requests that this Probable Violation Item #5, associated Proposed Compliance Order and associated Proposed Civil Penalty be rescinded from CPF 3- 2023-022. Item #6: § 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. Magellan failed to inspect and test two devices at its Roland, Iowa facility for calendar year 2020. During the field inspection and records review of Roland, Iowa, facility, PHMSA found that two devices, thermal relief MLBV 64 and thermal relief MLBV 65, were not inspected and tested. This is a repeat violation found in CPF# 320195007 Item 2. MAGELLAN RESPONSE: Magellan requests that PHMSA remove the “repeat violation” factor from its penalty calculation and reduce the total in the Civil Penalty Calculation for Item #6, accordingly. The citation in CPF# 3-2019-5007, Item 2 involved CFR 195.428(c) for 2#

32023022NOPV_Op Resp to Notice and Req for Hearing_09222023_(22-234357).pdf, page 3missing overfill protection inspections on pressure vessels in Des Moines, Iowa, whereas Item 6 is associated with CFR 195.428(a) involving thermal relief valve inspection records on block valves in Roland, Iowa. Magellan asserts that these devices are distinct in function and operational use, and are located at distinct and different facilities. Magellan appreciates the opportunity to respond and proactively work through the alleged violations with PHMSA in an effort to make the hearing unnecessary. If you have any questions or need additional information, please contact me by phone at (918) 574-7073 or e-mail at mark.materna@magellanlp.com to discuss. Sincerely, Mark Materna Director, Pipeline Integrity Cc: Jason Smith, Vice President, Asset Integrity, Magellan 3#

32023022NOPV_Closure Letter_10082024_(22-234357)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: Pierce.Norton@oneok.com; Mark.Materna@oneok.com; Danny.Scroggins@oneok.com October 8, 2024 Mr. Pierce Norton Chief Executive Officer ONEOK, Inc. 100 West Fifth Street Tulsa, Oklahoma 74109 RE: CPF 3-2023-022-NOPV Dear Mr. Norton: On January 22, 2024, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued a Consent Order incorporating the terms of the Consent Agreement entered into between PHMSA and Magellan Midstream Partners, LP (Magellan) in the above-referenced case. This Order included a Compliance Order and Civil Penalty assessment. Based on our review of the documentation provided by your staff, and confirmation of payment of the civil penalty on February 2, 2024, it has been determined that Magellan has complied with the terms of this Consent 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, Gregory A. Ochs Director, Central Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Mr. Mark Materna, Director, Pipeline Integrity, Mark.Materna@oneok.com Danny Scroggins, Esq., Senior Attorney, ONEOK, Danny.Scroggins@oneok.com#

32023022NOPV_PHC Hearing Scheduled_10162023_(22-234357)_text.pdf, page 1Official PDFOctober 16, 2023 VIA ELECTRONIC MAIL TO: mark.materna@magellanlp.com and gregory.ochs@dot.gov Mr. Mark Materna Director, Pipeline Integrity Magellan Midstream Partners, LP One Williams Center, MD: OTC-9 Tulsa, OK 74172 Mr. Gregory Ochs Director, Central Region Pipeline and Hazardous Materials Safety Administration 901 Locust Street, Suite 480 Kansas City, MO 64106 Re: Notice of Hearing, Magellan Midstream Partners, LP CPF No. 3-2023-022-NOPV Dear Mr. Materna and Mr. Ochs: In accordance with 49 C.F.R. § 190.211, an informal hearing will be held regarding the Notice of Probable Violation and Proposed Civil Penalty issued by the Pipeline and Hazardous Materials Safety Administration in the above-referenced case. The hearing will take place on May 9th, 2024, beginning at 8:30 a.m. Central Time. The hearing will be held at the PHMSA Central Region office, 901 Locust Street, Suite 480, Kansas City, Missouri 64106. Upon arrival at the building, attendees will be required to present photo identification to security personnel. A contact phone number for the day of the hearing is (816) 329- 3800. At least 10 calendar days prior to the hearing (or by April 29th, 2024), both parties must submit and exchange any additional written materials they intend to present at the hearing and the name and email address of each attendee. This information should be provided electronically. Materials not submitted by this date may be excluded. If you have any questions, please do not hesitate to contact me. Sincerely, Larry White Presiding Official#

32023022NOPV_PHC Hearing Scheduled_10162023_(22-234357)_text.pdf, page 2cc: Mr. Aaron Milford, Chief Executive Officer, Magellan Midstream Partners, LP, aaron.milford@magellanlp.com Mr. Ryan McClure, Counsel, Central Region, Office of Pipeline Safety, PHMSA, ryan.mcclure@dot.gov#