# VIKING GAS TRANSMISSION CO — Notice of Amendment

- **operation:** document
- **citation:** CPF 32024063NOA
- **title:** VIKING GAS TRANSMISSION CO — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2024-08-20
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 192.605(b)(2), 192.907(a), 192.907(b).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-32024063noa.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-32024063noa.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-32024063noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/32024063NOA
**body:**

Notice of Amendment involving VIKING GAS TRANSMISSION CO. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(2),  192.907(a),  192.907(b). The case was opened on 2024-08-20 and is reported as closed as of 2024-11-22. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

32024063NOA_Closure Letter_11222024_(23-264832).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024063NOA/32024063NOA_Closure%20Letter_11222024_(23-264832).pdf

32024063NOA_Closure Letter_11222024_(23-264832)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024063NOA/32024063NOA_Closure%20Letter_11222024_(23-264832)_text.pdf

32024063NOA_Notice of Amendment_08202024_(23-264832).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024063NOA/32024063NOA_Notice%20of%20Amendment_08202024_(23-264832).pdf

32024063NOA_Notice of Amendment_08202024_(23-264832)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024063NOA/32024063NOA_Notice%20of%20Amendment_08202024_(23-264832)_text.pdf

32024063NOA_Operator Response to Notice and Request for Hearing and Request an Informal Settlement Consultation_09192024_(23-264832).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024063NOA/32024063NOA_Operator%20Response%20to%20Notice%20and%20Request%20for%20Hearing%20and%20Request%20an%20Informal%20Settlement%20Consultation_09192024_(23-264832).pdf

32024063NOA_Operator Withdrawal of Hearing Request_10042024_(23-264832).pdf: https://primis.phmsa.dot.gov/enforcement-documents/32024063NOA/32024063NOA_Operator%20Withdrawal%20of%20Hearing%20Request_10042024_(23-264832).pdf

32024063NOA_Notice of Amendment_08202024_(23-264832)_text.pdf

NOTICE OF AMENDMENT
VIA ELECTRONIC MAIL TO: pierce.norton@oneok.com; scott.schingen@oneok.com;
roger.thorp@oneok.com; teri.anderson@oneok.com
August 20, 2024
Pierce H. Norton II
President and Chief Executive Officer
ONEOK, Inc.
100 West Fifth Street
Tulsa, Oklahoma 74103
CPF 3-2024-063-NOA
Dear Mr. Norton:
From February 27 through October 16, 2023, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code
(U.S.C.), inspected the Viking Gas Transmission Company (VGT) pipeline. VGT is a subsidiary
of ONEOK, Inc. The system inspected is located in the states of Wisconsin and North Dakota.
As a result of the inspection, PHMSA has identified the apparent inadequacies found within
VGT’s plans or procedures. The items inspected and the inadequacies are described below:
1. § 192.605 Procedural manual for operations, maintenance, and emergencies.
Each operator shall include the following in its operating and maintenance plan:
(a) . . . .
(b) Maintenance and normal operations. The manual required by paragraph (a) of this
section must include procedures for the following, if applicable, to provide safety
during maintenance and operations.
(1) . . . .
(2) Controlling corrosion in accordance with the operations and maintenance
requirements of subpart I of this part.
VGT’s procedural manual for operations, maintenance, and emergencies was inadequate as it did
not include adequate procedures for “[c]ontrolling corrosion in accordance with the operations
and maintenance requirements of subpart I,” per §§ 192.605(a) and (b)(2). Subpart I
“Requirements for Corrosion Control,” includes § 192.469, “External corrosion control: Test



stations.” Specifically, VGT’s procedure, entitled “Corrosion Control Standard,” was inadequate
because it failed to identify criteria to determine if a sufficient number of test stations currently
existed for electrical measurement to determine the adequate cathodic protection, as required by
§ 192.469. VGT’s Corrosion Control Standard Appendix D failed to (1) identify a method for
determining sufficient number of test points, and (2) prescribe when additional cathodic
protection surveys are required to determine the adequacy of the cathodic protection. The
procedure must be amended to provide criteria for identifying if a sufficient number of test
stations are available and to clarify when additional cathodic protection surveys are required.
2. § 192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered pipeline
segment must develop and follow a written integrity management program that
contains all the elements described in § 192.911 and that addresses the risks on each
covered transmission pipeline segment. The initial integrity management program
must consist, at a minimum, of a framework that describes the process for
implementing each program element, how relevant decisions will be made and by
whom, a time line for completing the work to implement the program element, and
how information gained from experience will be continuously incorporated into the
program. The framework will evolve into a more detailed and comprehensive
program. An operator must make continual improvements to the program.
VGT’s “Natural Gas Integrity Management Plan Appendix – Procedures” (NG IMP Appendix)
was inadequate because it failed to include timelines for completing the work to implement the
required program element, per the requirements of § 192.907(a). Specifically, NG IMP Appendix
Procedure 63, entitled “Data Integration,” section 5 failed to identify when a pre-assessment
evaluation must be conducted or when a post-assessment evaluation must be completed. By not
establishing a time frame or trigger condition to conduct or complete either the pre-assessment
evaluation or post-assessment evaluation, VGT personnel will not know when these processes
must be conducted. The procedure must be amended to include a time frame or trigger to
conduct and complete the pre-assessment evaluation and post-assessment evaluation.
3. § 192.907 What must an operator do to implement this subpart?
(a) General. No later than December 17, 2004, an operator of a covered pipeline
segment must develop and follow a written integrity management program that
contains all the elements described in § 192.911 and that addresses the risks on each
covered transmission pipeline segment. The initial integrity management program
must consist, at a minimum, of a framework that describes the process for
implementing each program element, how relevant decisions will be made and by
whom, a time line for completing the work to implement the program element, and
how information gained from experience will be continuously incorporated into the
program. The framework will evolve into a more detailed and comprehensive
program. An operator must make continual improvements to the program.



VGT’s NG IMP Appendix was inadequate because it did not include all of the elements
described in § 192.911, per the requirements of § 192.907(a). Section 192.911(c), “What are the
elements of an integrity management program?,” requires operators to use threat identification
and risk assessment, per § 192.917. VGT’s NG IMP Appendix failed to address the threat of
lamination (mid wall indications), as required by § 192.917. Lamination is an identified threat
under ASME B31.85 (incorporated by reference), as it is a “manufacturing related defect.”
Specifically, VGT’s NG IMP Appendix Procedure 53 failed to include an evaluation method or
repair criteria for the threat of lamination. The procedure must be amended to include an
evaluation method and repair criteria for the threat of lamination.
4. § 192.907 What must an operator do to implement this subpart?
(a) . . . .
(b) Implementation Standards. In carrying out this subpart, an operator must follow
the requirements of this subpart and of ASME B31.8S (incorporated by reference,
see § 192.7) and its appendices, where specified. An operator may follow an
equivalent standard or practice only when the operator demonstrates the alternative
standard or practice only when the operator demonstrates the alternative standard
or practice provides an equivalent level of safety to the public and property. In the
event of a conflict between this subpart and ASME B31.8S, the requirements in this
subpart control.
VGT’s NG IMP Appendix was found to be inadequate because it failed to define when and how a
“response plan shall be developed,” as required by §§ 192.907(a) and (b), and ASME B31.8S
(incorporated by reference in § 192.7). Specifically, VGT’s NG IMP Appendix Procedure 53
referenced a remediation plan, but failed to prescribe plan requirements. Additionally, VGT’s NG
IMP App Procedure 63 referenced a remediation schedule, but failed to prescribe schedule
requirements. Thus, VGT’s NG IMP Appendix failed to provide adequate guidance concerning
time frames for physical examination of anomalies. The procedures must be modified to include a
response plan and schedule for anomalous conditions identified during the assessment.
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
90 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 that VGT maintain documentation of the safety improvement costs associated
with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit
the total to Gregory A. Ochs, Director, Central Region, Pipeline and Hazardous Materials Safety
Administration. In correspondence concerning this matter, please refer to CPF 3-2024-063-NOA
and, for each document you submit, please provide a copy in electronic format whenever
possible.
Sincerely,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Scott Schingen, Senior VP of Natural Gas Liquids and Natural Gas Operations, ONEOK,
(scott.schingen@oneok.com)
Roger Thorp, VP of Natural Gas Operations, ONEOK, (roger.thorp@oneok.com)
Teri Anderson, Senior Manager of DOT Compliance Services, ONEOK,
(teri.anderson@oneok.com)
Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings

32024063NOA_Closure Letter_11222024_(23-264832)_text.pdf

VIA ELECTRONIC MAIL TO: pierce.norton@oneok.com; scott.schingen@oneok.com;
roger.thorp@oneok.com; teri.anderson@oneok.com
November 22, 2024
Pierce H. Norton II
President and Chief Executive Officer
ONEOK, Inc.
100 West Fifth Street
Tulsa, Oklahoma 74103
RE: CPF 3-2024-063-NOA
Dear Mr. Norton:
From February 27 through October 16, 2023, a representative of the Pipeline and Hazardous
Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code
(U.S.C.), inspected the Viking Gas Transmission Company (VGT) pipeline. VGT is a subsidiary
of ONEOK, Inc. The system inspected is located in the states of Wisconsin and North Dakota.
As a result of the inspection, VGT was issued a Notice of Amendment on August 20, 2024,
which proposed amendment of your procedures.
VGT submitted its amended procedures on November 22, 2024. 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 that no further action is necessary, and this case is now closed.
Thank you for your cooperation.
Sincerely,
Gregory A. Ochs
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Scott Schingen, Senior VP of Natural Gas Liquids and Natural Gas Operations, ONEOK,
(scott.schingen@oneok.com)
Roger Thorp, VP of Natural Gas Operations, ONEOK, (roger.thorp@oneok.com)
Teri Anderson, Senior Manager of DOT Compliance Services, ONEOK,
(teri.anderson@oneok.com)
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