ONEOK NGL PIPELINE, LLC — Notice of Probable Violation

party submissionOfficial PDF420125028_Operator Response to Notice_09282012.pdf#

420125028_NOPV PCP PCO_09122012_text.pdf, page 1Official PDFNOTICE OF PROBABLE VIOLATION PROPOSED CIVIL PENALTY and PROPOSED COMPLIANCE ORDER CERTIFIED MAIL - RETURN RECEIPT REQUESTED September 12, 2012 Mr. Wes Christensen Senior Vice President, NGL Operations ONEOK Partners, NGL Pipeline L.P. 100 West Fifth Street Tulsa, OK 74102 CPF 4-2012-5028 Dear Mr. Christensen: On multiple occasions between September 2011 through January 20, 2012, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code were onsite and inspected your Operations and Maintenance Manual, records and pipeline facilities in Oklahoma and Texas. As a result of the inspection, it appears that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the probable violation(s) are: 1. §195.589 What corrosion control information do I have to maintain? (c) You must maintain a record of each analysis, check, demonstration, examination, inspection, investigation, review, survey, and test required by this subpart in sufficient detail to demonstrate the adequacy of corrosion control measures or that corrosion requiring control measures does not exist. You must#

420125028_NOPV PCP PCO_09122012_text.pdf, page 2retain these records for at least 5 years, except that records related to §§195.569, 195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as long as the pipeline remains in service. ONEOK failed to maintain records with sufficient detail to demonstrate the adequacy of corrosion control measures of their pipeline system. The Operator informed PHMSA during the inspection that certain records required by 49 CFR 195.589 were missing. These records consisted of data collected during the annual pipe-to-soil surveys carried out on the Arbuckle Pipeline during September through October 2010 between approximate mileposts (MP) 266 and 439. Some of the missing records were related to data lost and unrecoverable due to a computer hard drive problem. Additionally, the operator learned that there were no records for the pipe-to-soil survey having been completed between approximately MP 109 and 176. 2. § 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. ONEOK did not follow their procedure for evaluating and remediating anomalous conditions that are discovered as a result of integrity assessments and information analysis. ONEOK’s, Procedure 3.2 Design and Operating Parameters, of their O&M Procedures for Hazardous Liquids, states that pipeline repairs will be made in accordance to NGLimp3.0001. NGLimp3.0001, Section 5: Assessment and Remediation states that anomalous conditions are evaluated and repaired in accordance with Procedure 53: Defect Evaluation and Repair. ONEOK’s Procedure 53: Defect Evaluation and Repair, Section 2.4.7.1, states how internal corrosion shall be evaluated. The procedure states to “Create a half-inch incremented grid circumferentially and axially” and to “Use a hand-held wall thickness verification meter or a UT device to determine the lowest wall thickness in each ½ in grid”. Section 2.4.7.1 demonstrates how to accomplish the grid and to use Figure 2 as an example. ONEOK personnel did not follow their procedures to evaluate for internal corrosion. During Dig Number CF-10-F4, ONEOK personnel did not document that a grid was completed during the UT scans of the pipe sections to locate the internal corrosion. Also, during Dig Number SMC- 2#

420125028_NOPV PCP PCO_09122012_text.pdf, page 308-05, ONEOK personnel did not document that a grid was completed during the UT scans of the pipe section to locate the internal corrosion. 3. §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. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. ONEOK did not follow their procedure for evaluating and repairing their pipeline while remediating anomalous condition in a non-high consequence area. ONEOK’s, Procedure 3.2 Design and Operating Parameters, of their O&M Procedures for Hazardous Liquids, states that pipeline repairs will be made in accordance to NGLimp3.0001. NGLimp3.0001, Section 5: Assessment and Remediation states that anomalous conditions are evaluated and repaired in accordance with Procedure 53: Defect Evaluation and Repair. First, ONEOK’s Procedure 53, Section 2.2.6, states that “NGL Ops must confirm that the selected anomaly is accurately located for each evaluation”. This can be accomplished by: comparison of predicted anomaly characteristics to the actual anomaly, comparison of length of target joint or nearby joint to the ILI data, comparison of distances to nearby features to ILI or alignment sheet data, comparison to previous assessment or repair data, or orientation of longitudinal seam weld. During Dig Number SMC-08-05 ONEOK personnel did not document or obtain sufficient data to accurately locate an anomaly. The documentation, “Pipeline Defect Evaluation & Repair Form,” states that no external or internal defect was found after completing a UT scan. There is no evidence of other confirmation methods utilized per the procedure to confirm the anomaly location was accurately located. 4. § 195.402 Procedural manual for operations, maintenance, and emergencies. 3#

420125028_NOPV PCP PCO_09122012_text.pdf, page 4(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. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (13) Periodically reviewing the work done by operator personnel to determine the effectiveness of the procedures used in normal operation and maintenance and taking corrective action where deficiencies are found. ONEOK did not follow their procedure on documentation of the periodic review of work done by personnel to determine the effectiveness of the procedures used in normal operation and maintenance and taking corrective action where deficiencies are found. ONEOK’s Procedure 3.1 General Procedures, Normal Operating Procedures Review, states that the ONP Business Manager or designee shall be responsible for conducting a review of the work done by personnel to determine the effectiveness of operating procedures at intervals not exceeding 15 months, but at least once each calendar year. In addition, the procedure states that the annual review documentation of these reviews will include the date, items discussed, changes and personnel in attendance. ONEOK did not have any documentation demonstrating the review of the work done by operator personnel to determine the effectiveness of the procedures used was being performed. Proposed Civil Penalty Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $100,000 for each violation for each day the violation persists up to a maximum of $1,000,000 for any 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 $15,300 for item 2. Warning Items With respect to items 1 and 4, PHMSA has reviewed the circumstances and supporting documents involved in this case and has decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to promptly correct these item(s). 4#

420125028_NOPV PCP PCO_09122012_text.pdf, page 5Be advised that failure to do so may result in ONEOK NGL Pipeline L.P. being subject to additional enforcement action. Proposed Compliance Order With respect to items 2 and 3 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. 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). 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. In your correspondence on this matter, please refer to CPF 4-2012-5028 and for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, R. M. Seeley Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Compliance Proceedings 5#

420125028_NOPV PCP PCO_09122012_text.pdf, page 6PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to ONEOK a Compliance Order incorporating the following remedial requirements to ensure the compliance of ONEOK with the pipeline safety regulations: 1. 2. 3. 4. In regard to Item Number 2 of the Notice pertaining to Dig Numbers SMC-08-05 and CF-10-F4 in which the evaluation for internal corrosion was not documented, the operator must re-evaluate the location of the anomalies for internal corrosion in accordance with their procedures. In regard to Item Number 3 of the Notice pertaining to the Dig Number SMC-08- 05, in which there was no confirmation methods utilized to confirm the correct location of the anomaly, the operator must do further evaluation in accordance with their procedures to confirm the correct location of the anomaly. ONEOK must complete items 1 and 2 within 180 days following receipt of the Final Order. 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 R. M. Seeley, Director, Southwest 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. 6#

420125028_Final Order_ 04222013_text.pdf, page 1Official PDFAPRIL 22, 2013 Mr. Wes Christensen Senior Vice President, NGL Operations ONEOK NGL Pipeline L.L.C 100 West Fifth Street Tulsa, OK 74102 Re: CPF No. 4-2012-5028 Dear Mr. Christensen: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation, assesses a civil penalty of $15,300 and specifies actions that need to be taken by ONEOK NGL Pipeline L.L.C. to comply with the pipeline safety regulations. This is to acknowledge receipt of payment of the full penalty amount, by wire transfer, dated October 22, 2012. It further finds that ONEOK NGL Pipeline, L.L.C. has completed the actions specified in the Notice to comply with the pipeline safety regulations. This enforcement action is now closed. Service of the Final Order by certified mail is deemed effective upon the date of mailing, or as otherwise provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Jeffrey D. Wiese Associate Administrator for Pipeline Safety Enclosure cc: Mr. Rodrick M. Seeley, Director, Southwest Region, OPS Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

420125028_Final Order_ 04222013_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 Partners, NGL Pipeline L.P., ) Respondent. ) ____________________________________) 1 ) CPF No. 4-2012-5028 FINAL ORDER Between September, 2011 and January 2012, pursuant to 49 U.S.C. § 60117, a representative 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 L.L.C. (ONEOK or Respondent), in Oklahoma and Texas. ONEOK owns and operates over 2400 miles of natural gas liquid pipelines that transport natural gas from production areas throughout Oklahoma, Kansas and Texas.2 As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to Respondent, by letter dated September 12, 2012, a Notice of Probable Violation, Proposed Civil Penalty, Proposed Compliance Order and warnings pursuant to 49 C.F.R. § 190.205 (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that ONEOK had committed various violations of 49 C.F.R. Part 195 and assessing a civil penalty of $15,300 for one of the alleged violations. The Notice also proposed ordering Respondent to take certain measures to correct the other alleged violations. The warning items required no further action but warned the operator to correct the probable violation or face future potential enforcement action. ONEOK responded to the Notice by letter dated September 28, 2012 (Response). The company did not contest the allegations of violation, paid the proposed civil penalty of $15,300, as provided in 49 C.F.R. § 190.227, and provided information showing that it had complied with the terms of the proposed Compliance Order. Payment of the penalty and completion of the Compliance Order, as approved by the Director, serves to close the case with prejudice to Respondent. 1 The initial Notice of Probable Violation was sent to ONEOK Partners, NGL Pipeline L.P.. Since receiving the Notice, the Operator has changed its name to ONEOK NGL Pipeline L.L.C. 2 See http://www.oneokpartners.com/Customers/NaturalGasLiquids/Pipelines/NGLPipeline.aspx (last accessed on April 10, 2013).#

420125028_Final Order_ 04222013_text.pdf, page 32 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 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.589, which states in relevant part: § 195.589 – What corrosion control information do I have to maintain? (c) You must maintain a record of each analysis, check, demonstration, examination, inspection, investigation, review, survey and test required by this subpart in sufficient detail to demonstrate the adequacy of corrosion control measures or that corrosion requiring control measures does not exist. You must retain these records for at least 5 years, except that records related to §§ 195.569, 195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as long as the pipeline remains in service. The Notice alleged that Respondent violated 49 C.F.R. § 195.589(c) by failing to maintain records with sufficient detail to demonstrate the adequacy of corrosion control measures on its pipeline system. Specifically, the Notice alleged that ONEOK was missing certain records that documented the annual pipe-to-soil surveys carried out on the Arbuckle Pipeline during October 2010. 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. § 195.589 by failing to maintain records with sufficient detail to demonstrate the adequacy of corrosion control measures on its pipeline system. Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), which states in relevant part: § 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 follow its own procedure for evaluating and remediating anomalous conditions discovered through integrity assessments and information analysis. Specifically, the Notice alleged that ONEOK violated 3.2#

420125028_Final Order_ 04222013_text.pdf, page 43 Design & Operating Parameters of its O&M Procedures when it failed to document that a grid was completed during the UT scans of the pipe section to locate internal corrosion. Section 2.4.7.1 of Procedure 53 (Defect Evaluation and Repair) states how internal corrosion shall be evaluated. The procedure states to create a half-inch incremented grid circumferentially and axially and to use a hand-held wall thickness verification meter or a UT device to determine the lowest wall thickness in each half-inch grid. On two separate occasions, ONEOK personnel did not follow this procedure. During Digs CF-10-F4 and SMC-208-05, ONEOK personnel did not document that a grid was completed during the UT scans to locate internal corrosion. 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 properly document that a grid was completed during the UT scans to locate the internal corrosion. Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(3), which states in relevant part: § 195.402 – Procedural manual for operations, maintenance, and emergencies. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(3) by failing to follow its own procedure for evaluating and repairing its pipeline while remediating anomalous conditions in a non-high consequence area. Specifically, the Notice alleged that ONEOK did not document or obtain sufficient data to accurately locate any anomalies as set forth in procedure 3.2 of its Design & Operating Parameters. Section 2.2.6 of Procedure 53 requires that each anomaly be accurately located for each evaluation. The procedure states that ONEOK’s personnel should compare the predicted anomaly characteristics to the actual anomaly. ONEOK personnel did not adequately follow this procedure. During Dig SMC-08-05, ONEOK personnel did not document or obtain sufficient data to accurately locate the anomaly. 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(c)(3) failing to document or obtain sufficient data to accurately locate an anomaly. Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(13), which states in relevant part: § 195.402 – Procedural manual for operations, maintenance, and emergencies. (a) General. Each shall prepare and follow for each pipeline system a manual of written procedures for conducting operations and maintenance activities and handling#

420125028_Final Order_ 04222013_text.pdf, page 54 abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once a year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operation of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. (b) … (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (13) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(13) by failing to follow its own procedures requiring that it periodically review the work done by personnel to determine the effectiveness of its operating procedures. Specifically, the Notice alleged that ONEOK violated Procedure 3.1 (General Procedures). Procedure 3.1 requires the Business Manager to be responsible for conducting a review of the work done by personnel, to determine the effectiveness of operating procedures at least once a year. The documents of these reviews will include the date, items discussed, changes and personnel attendance. During the OPS inspection, ONEOK could not produce any of the necessary documentation. 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(c)(13) by failing to periodically review the work done by its personnel to determine the effectiveness of its operating procedure 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 $100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any related series of violations. 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; the Respondent’s ability to pay the penalty 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 $15,300 for Item #2 cited above. Item 2: The Notice proposed a civil penalty of $15,300 for Respondent’s violation of#

420125028_Final Order_ 04222013_text.pdf, page 65 49 C.F.R. § 195.402(a), for failing to follow their procedure for evaluating and remediating anomalous conditions that are discovered as a result of integrity assessments and information analysis. ONEOK did not contest the proposed penalty amount. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $15,300 for violation of 49 C.F.R. § 195.402(a), which has already been remitted. In summary, having reviewed the record and considered the assessment criteria for the Item cited above, I assess Respondent a total civil penalty of 15,300, which has been paid in full. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Items 2 and 3 in the Notice for violations of 49 C.F.R. §195.402(a) and (c), respectively. Under 49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquid or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. The Director indicates that Respondent has taken the following actions specified in the proposed compliance order: 1. With respect to the violation of § 195.402(a) (Item 2), Respondent has re- evaluated the location of the anomalies for internal corrosion at Dig Numbers SMC- 08-05 and CF-10-F4 in accordance with its procedures. 2. With respect to the violation of § 195.402(c) (Item 3), Respondent has conducted further evaluation methods, in accordance with its procedures, to confirm the correct location of the anomaly pertaining to Dig Number SMC-08-05. Accordingly, I find that compliance has been achieved with respect to these violations. Therefore, the compliance terms proposed in the Notice are not included in this Order. WARNING ITEMS With respect to Items 1 and 4, 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. § 195.589 (Item 1) ─ Respondent’s alleged failure to maintain records with sufficient detail to demonstrate the adequacy of corrosion control measures on its pipeline system; and 49 C.F.R. § 195.402(c)(13) (Item 4) ─ Respondent’s alleged failure to follow its own procedures, requiring that it periodically review the work done by personnel to determine the effectiveness of its own procedures.#

420125028_Final Order_ 04222013_text.pdf, page 76 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. ___________________________________ __________________________ Jeffrey D. Wiese Date Issued Associate Administrator for Pipeline Safety#

420125028_Final Order_04222013.pdf, page 1Official PDFof Transportation U.S. Department 1200 New Jersey Avenue, SE Washington, D.C. 20590 Pipeline and Hazardous Administration Materials Safety APR 22 2013 Mr. Wes Christensen Senior Vice President, NGL Operations ONEOK NGL Pipeline L.L.C 100 West Fifth Street Tulsa, OK 74102 Re: CPF No. 4-2012-5028 Dear Mr. Christensen: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation, assesses a civil penalty of $15,300 and specifies actions that need to be taken by ONEOK NGL Pipeline L.L.C. to comply with the pipeline safety regulations. This is to acknowledge receipt of payment of the full penalty amount, by wire transfer, dated Uctober 22, 2012. It further finds that ONEOK NGL Pipeline, L.L.C. has completed the actions spected it the ceo to comply with the peptine sail segulaid s. hive upon the dacoin is mailing, or as otherwise provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Jeffrey D. Wiese Associate Administrator for Pipeline Safety Enclosure CC: Mr. Rodrick M. Seeley, Director, Southwest Region, OPS Mr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS CERTIFIED MAIL - RETURN RECEIPT REQUESTED#

420125028_Final Order_04222013.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 Partners, NGL. Pipeline L.P.,' CPF No. 4-2012-5028 Respondent. FINAL ORDER Between September, 2011 and January 2012, pursuant to 49 U.S.C. § 60117, a representative 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 L.L.C. (ONEOK or Respondent), in Oklahoma and Texas. ONEOK owns and operates over 2400 miles of natural gas liquid pipelines that transport natural gas from production areas throughout Oklahoma, Kansas and Texas? As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to Respondent, by letter dated September 12, 2012, a Notice of Probable Violation, Proposed Civil Penalty, Proposed Compliance Order and warnings pursuant to 49 C.F.R. § 190.205 (Notice). In accordance with 49 C.F.R. § 190.207, the Notice proposed finding that ONEOK had committed various violations of 49 C.F.R. Part 195 and assessing a civil penalty of $15,300 for one of the alleged violations. The Notice also proposed ordering Respondent to take certain measures to correct the other alleged violations. The warning items required no further action but warned the operator to correct the probable violation or face future potential enforcement action. ONEOK responded to the Notice by letter dated September 28, 2012 (Response). The company did not contest the allegations of violation, paid the proposed civil penalty of $15,300, as provided in 49 C.F.R. § 190.227, and provided information showing that it had complied with the terms of the proposed Compliance Order. Payment of the penalty and completion of the Compliance Order, as approved by the Director, serves to close the case with prejudice to Respondent. ' The initial Notice of Probable Violation was sent to ONEOK Partners, NGL Pipeline L.P.. Since receiving the Notice, the Operator has changed its name to ONEOK NGL Pipeline L.L.C. ' See http://www.oneokpartners.com/Customers/NaturalGasLiquids/Pipelines/NGLPipeline.aspx (last accessed on April 10, 2013).#

420125028_Final Order_04222013.pdf, page 32 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 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.589, which states in relevant part: § 195.589 - What corrosion control information do I have to maintain? (C) You must maintain a record of each analysis, check, demonstration, examination, inspection, investigation, review, survey and test required by this subpart in sufficient detail to demonstrate the adequacy of corrosion control measures or that corrosion requiring control measures does not exist. You must retain these records for at least 5 years, except that records related to §§ 195.569, 195.573(a) and (b), and 195.579(b)(3) and (c) must be retained for as long as the pipeline remains in service. The Notice alleged that Respondent violated 49 C.F.R. § 195.589(c) by failing to maintain ecords with sufficient detail to demonstrate the adequacy of corrosion control measures on it: ipeline system. Specifically, the Notice alleged that ONEOK was missing certain records tha documented the annual pipe-to-soil surveys carried out on the Arbuckle Pipeline during October 2010. 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. § 195.589 by failing to maintain records with sufficient detail to demonstrate the adequacy of corrosion control measures on its pipeline system. Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a), which states in relevant part: § 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, activities are conducted and appropriate parts shall be kept at locations where operations and maintenance The Notice alleged that Respondent violated 49 C.F.R. § 195.402(a) by failing to follow its own procedure for evaluating and remediating anomalous conditions discovered through integrity assessments and information analysis. Specifically, the Notice alleged that ONEOK violated 3.2#

420125028_Final Order_04222013.pdf, page 43 Design & Operating Parameters of its O&M Procedures when it failed to document that a grid was completed during the UT scans of the pipe section to locate internal corrosion. Section 2.4.7.1 of Procedure 53 (Defect Evaluation and Repair) states how internal corrosion shall be evaluated. The procedure states to create a half-inch incremented grid circumferentially and axially and to use a hand-held wall thickness verification meter or a UT device to determine the lowest wall thickness in each half-inch grid. On two separate occasions, ONEOK personnel did not follow this procedure. During Digs CF-10-F4 and SMC-208-05, ONEOK personnel did not document that a grid was completed during the UT scans to locate internal corrosion. 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 properly document that a grid was completed during the UT scans to locate the internal corrosion. Item 3: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(3), which states in relevant part: § 195.402 - Procedural manual for operations, maintenance, and emergencies. (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(3) by failing to follow its own procedure for evaluating and repairing its pipeline while remediating anomalous conditions in a non-high consequence area. Specifically, the Notice alleged that ONEOK did not document or obtain sufficient data to accurately locate any anomalies as set forth in procedure 3.2 of its Design & Operating Parameters. Section 2.2.6 of Procedure 53 requires that each anomaly be accurately located for each evaluation. The procedure states that ONEOK's personnel should compare the predicted anomaly characteristics to the actual anomaly. ONEOK personnel did not adequately follow this procedure. During Dig SMC-08-05, ONEOK personnel did not document or obtain sufficient data to accurately locate the anomaly. 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(c)(3) failing to document or obtain sufficient data to accurately locate an anomaly. Item 4: The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(13), which states in relevant part: § 195.402 - Procedural manual for operations, maintenance, and emergencies. (a) General. Each shall prepare and follow for each pipeline system a manual of written procedures for conducting operations and maintenance activities and handling#

420125028_Final Order_04222013.pdf, page 5abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once a year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operation of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. (b) ... (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (13) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. The Notice alleged that Respondent violated 49 C.F.R. § 195.402(c)(13) by failing to follow its own procedures requiring that it periodically review the work done by personnel to determine the Procedure 3.1 (General Procedures). effectiveness of its operating procedures. Specifically, the Notice alleged that ONEOK violated Procedure 3.1 requires the Business Manager to be responsible for conducting a review of the rear. The documents of these reviews will include the date, items discussed, changes an vork done by personnel, to determine the eftectiveness of operating procedures at least once personnel attendance. During the OPS inspection, ONEOK could not produce any of the necessary documentation. Respondent did not contest this allegation of violation. Accordingly, based upon a review of all I the evidence, I find that Respondent violated 49 C.F.R. § 195.402(c)(13) by failing t eriodically review the work done by its personnel to determine the effectiveness of its operatin procedure 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 $100,000 per violation for each day of the violation, up to a maximum of $1,000,000 for any related series of violations. 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; the Respondent's ability to pay the penalty 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 $15,300 for Item #2 cited above. Item 2: The Notice proposed a civil penalty of $15,300 for Respondent's violation of#

420125028_Final Order_04222013.pdf, page 65 49 C.F.R. § 195.402(a), for failing to follow their procedure for evaluating and remediating anomalous conditions that are discovered as a result of integrity assessments and information analysis. ONEOK did not contest the proposed penalty amount. Accordingly, having reviewed the record and considered the assessment criteria, I assess Respondent a civil penalty of $15,300 for violation of 49 C.F.R. § 195.402(a), which has already been remitted. In summary, having reviewed the record and considered the assessment criteria for the Item cited above, I assess Respondent a total civil penalty of 15,300, which has been paid in full. COMPLIANCE ORDER The Notice proposed a compliance order with respect to Items 2 and 3 in the Notice for violations of 49 C.F.R. §195.402(a) and (c), respectively. Under 49 U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquid or who owns or operates a pipeline facility is required to comply with the applicable safety standards established under chapter 601. The Director indicates that Respondent has taken the following actions specified in the proposed compliance order: 1. With respect to the violation of § 195.402(a) (Item 2), Respondent has re- evaluated the location of the anomalies for internal corrosion at Dig Numbers SMC- 08-05 and CF-10-F4 in accordance with its procedures. 2. With respect to the violation of § 195.402(c) (Item 3), Respondent has conducted further evaluation methods, in accordance with its procedures, to confirm the correct location of the anomaly pertaining to Dig Number SMC-08-05. Accordingly, I find that compliance has been achieved with respect to these violations. Therefore, the compliance terms proposed in the Notice are not included in this Order. WARNING ITEMS With respect to Items 1 and 4, 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. § 195.589 (Item 1) - Respondent's alleged failure to maintain records with sufficient detail to demonstrate the adequacy of corrosion control measures on its pipeline system; and 49 C.F.R. § 195.402(c)(13) (Item 4) - Respondent's alleged failure to follow its own procedures, requiring that it periodically review the work done by personnel to determine the effectiveness of its own procedures.#

420125028_Final Order_04222013.pdf, page 76 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. well APR 22 2013 Jeffrey D. Wiese Date Issued Associate Administrator for Pipeline Safety#