{"operation":"document","citation":"CPF 420135020W","title":"ONEOK NGL PIPELINE, LLC — Warning Letter","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2013-09-26","effective_on":null,"summary":"CLOSED warning letter citing 195.202, 195.222, 195.234(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135020w.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135020w.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135020w","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420135020W","body":"Warning Letter involving ONEOK NGL PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.202,  195.222,  195.234(c). The case was opened on 2013-09-26 and is reported as closed as of 2013-09-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420135020W_Warning_09262013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135020W/420135020W_Warning_09262013.pdf\n\n420135020W_Warning_09262013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135020W/420135020W_Warning_09262013_text.pdf\n\n420135020W_Warning_09262013_text.pdf\n\nWARNING LETTER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 26, 2013\nMr. Wes Christensen\nVice President, NGL Operations\nOneok NGL Pipeline, LLC\n100 West Fifth Street\nTulsa, OK, 784102\nCPF 4-2013-5020W\nDear Mr. Christensen:\nOn various dates in 2013, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected\nconstruction of your Sterling III pipeline in Oklahoma.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violation(s) are:\n1. §195.222 Welders: Qualification of welders.\n(a) Each welder must be qualified in accordance with section 6 of API 1104 (ibr, see §\n195.3 or section IX of the ASME Boiler and Pressure Vessel Code, (ibr, see § 195.3)\nexcept that a welder qualified under an earlier edition than listed in § 195.3 may\nweld but may not re-qualify under that earlier edition.\n(b) No welder may weld with a welding process unless, within the preceding 6 calendar\nmonths, the welder has —\n\n\n\n(1) Engaged in welding with that process; and\n(2) Had one welded tested and found acceptable under section 9 of API 1104 (ibr,\nsee § 195.3).\nONEOK did not follow its ONP Welding Manual STD 1602.200 & TG1602.201 section 6.2\nWelder Qualification, which requires that “Welders be qualified in accordance with API\nStandard 1104, Section 6.”\nONEOK used welders that were not properly qualified in accordance with section 6 of API 1104\nto construct a portion of the 16-inch Sterling III Pipeline. ONEOK performed welder\nqualifications on April 9, 2013, for Mr. David A. Uriegas and John Robert Miller using the\nsingle qualification provisions in API 1104 section 6.2. According to section 6.2 of API 1104, if\nan essential welder qualification variable is changed, the welder must be re-qualified. API 1104\nsection 6.2.2 defines the essential variable groupings for outside diameter pipe to be 12.75-inches\nor less and greater than 12.75 inches for a welder single qualification. The welder qualifications\nwere performed on 12.75-inch outside diameter pipe but the pipe being used to construct the\nSterling III Pipeline is 16 - inch. By qualifying the welders on 12.75 inch diameter pipe using\nthe single qualification provisions, the welders were not qualified to weld on the 16-inch\ndiameter pipe used to construct the 16 inch Sterling III Pipeline.\nThe welder qualification record for Mr. David A. Uriegas shows that he passed a single\nqualification test (butt weld) on April 9, 2013. According to the Shaw Pipeline Services\nnondestructive testing report, Mr. Uriegas welded Sterling III 16-inch pipe on April 20, 2013.\nMr. Uriegas’ welder qualification record indicates he then passed a branch weld qualification test\non April 28, 2013. While this test and the butt weld qualification test previously passed qualify\nthe welder to weld on any diameter pipe, the second test was passed after completing at least five\nwelds on the Sterling III 16-inch pipe, making Mr. Uriegas unqualified to make these production\nwelds on the 16-inch pipe. Similarly, Mr. John Robert Miller passed a single qualification test\non April 9, 2013. According to the Shaw Pipeline Services nondestructive testing report, Mr.\nMiller welded Sterling III 16-inch pipe on April 12, 2013. Mr. Miller also subsequently passed a\nbranch weld qualification test on April 20, 2013, but according to the provisions of API 1104\nwas not qualified to make production welds on the 16-inch pipe on April 12, 2013. There are no\nprovisions in Part 195 or API 1104, incorporated by reference, allowing a welder to retroactively\npass a qualification test and then claim previous welds made as an unqualified welder are\nacceptable.\n2. §195.202 Compliance with specifications or standards.\n(a) Each pipeline system must be constructed in accordance with comprehensive\nwritten with comprehensive specifications or standards that are consistent with the\nrequirements of this part.\n2\n\n\n\nOneok did not follow its NGL O&M coating procedure. There were several locations in which\nthe contractor did not follow Oneok coating specifications. Specifically, weld blankets were not\nbeing utilized to protect the existing coating on the pipe to prevent weld splatter from damaging\nthe coating. Oneok’s NGL O&M section 2.11 states that all coating used or recommended shall\nmeet at the minimum the requirements of 195.557 which is as follows:\n(a) Each external protective coating, whether conductive or insulating, applied for the\npurpose of external corrosion control must:\n(1) Be applied on a properly prepared surface;\n(2) Have sufficient adhesion to the metal surface to effectively resist under film migration\nof moisture\nDuring the PHMSA inspection, it was noted that several girth welds had coating damage due to\nweld splatter. Good construction procedures require coatings on piping to be protected to\nminimize damage that may result from the welding operations which was not being followed by\nthe contractor.\n3. §195.234 Welds: Nondestructive testing.\n(a) Procedures for the proper interpretation of each weld inspection must be\nestablished to ensure the acceptability of the weld under §195.228.\nOneok did not have procedures to thoroughly address the new Real Time Radiography (RTR)\nprocesses being used.\nObservations of the Shaw RTR digital X-ray system on ONEOK Sterling III in Durant, OK\nrevealed the following deficiencies which should be addressed in construction procedures:\nYour procedures must include potential problems associated with electrical interference and\nnoise (e.g. high voltage lines, induction heating, welding), severe environmental conditions (e.g.\nshock, dust, mud, rain, moisture, temperature extremes), appropriate limits for radiographer to\nadjust system parameters, user error, software bugs, and mechanical failures.\nProcedural methods need to be developed to mitigate the potential for thermal shutdown based\non the following observations. The mainline RTR crew (single wall system) was placing ice on\nthe system to cool it down to avoid thermal shutdown. The system was at 33 degrees Celsius (91\ndegrees Fahrenheit) and shutdown occurs at 35 degrees Celsius (95 degrees Fahrenheit). The\nweather was sunny and 91 degrees Fahrenheit. As the project proceeds, hotter days may pose a\nproblem. The mainline crew stated if the single wall system overheats, they will use the double\nwall system. Higher temperatures increase sensor noise, which degrades the image. The\nprocedure need to address this in a way to ensure consistent implementation.\n3\n\n\n\nOneok should review their RTR procedures to ensure all other procedural requirements\nnecessary for the consistent and reliable use of RTR technology.\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 4, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. Also, for LNG facilities, an additional penalty of not more than\n$50,000 for each violation may be imposed. We have reviewed the circumstances and\nsupporting documents involved in this case, and have decided not to conduct additional\nenforcement action or penalty assessment proceedings at this time. We advise you to correct the\nitem(s) identified in this letter. Failure to do so will result in Oneok NGL Pipeline, LLC being\nsubject to additional enforcement action.\nNo reply to this letter is required. If you choose to reply, in your correspondence please refer to\nCPF 4-2013-5020W. Be advised that all material you submit in response to this enforcement\naction is subject to being made publicly available. If you believe that any portion of your\nresponsive material qualifies for confidential treatment under 5 U.S.C. 552(b), along with the\ncomplete original document you must provide a second copy of the document with the portions\nyou believe qualify for confidential treatment redacted and an explanation of why you believe\nthe redacted information qualifies for confidential treatment under 5 U.S.C. 552(b).\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n4","truncated":false,"body_characters":9087}