ONEOK NGL PIPELINE, LLC — Safety Order

party submissionOfficial PDF420165014S_Operator Request for Hearing_05302017.pdf#

party submissionOfficial PDF420165014S_Operator Response to Notice_08242016.pdf#

420165014S_Consent Agreement and Order_12132019_text.pdf, page 1Official PDFDecember 13, 2019 VIA EMAIL AND CERTIFIED MAIL: Mr. Scott Schingen Vice President, Natural Gas Liquids Operations ONEOK NGL Pipeline, L.L.C. 100 W. Fifth Street Tulsa, Oklahoma 74103 RE: In the Matter of ONEOK NGL Pipeline, L.L.C. – CPF No. 4-2016-5014S Dear Mr. Schingen: Enclosed please find the fully executed Consent Agreement and Order that resolves the issues underlying the Notice of Proposed Safety Order issued by PHMSA on May 16, 2016, in the above-referenced proceeding. Your receipt of this Consent Agreement and Order constitutes service, as provided under 49 C.F.R. § 190.5. Thank you for your cooperation in this matter. Sincerely, Alan K. Mayberry Associate Administrator for Pipeline Safety Enclosure cc: Ms. Mary McDaniel, Director, Southwest Region, Office of Pipeline Safey, PHMSA Ms. Linda Daugherty, Deputy Associate Administrator for Field Operations, Pipeline Safety, Office of Pipeline Safety, PHMSA Mr. Walter Allen, Vice President, Natural Gas Liquids Transportation Mr. David Keglovits, Vice President and Associate General Counsel Mr. Vince Murchison, Murchison Law Firm, 325 North St. Paul Street, Suite 2700, Dallas, Texas 75201#

420165014S_Consent Agreement and Order_12132019_text.pdf, page 2U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ In the Matter of ) ONEOK NGL Pipeline, L.L.C. ) CPF No. 4-2016-5014S ) ) ) Respondent ) ____________________________________) CONSENT AGREEMENT AND ORDER On May 16, 2016, pursuant to 49 C.F.R. § 190.239, the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), issued a Notice of Proposed Safety Order (Notice) to ONEOK NGL Pipeline, L.L.C. (Respondent). The Notice alleged that Respondent’s 16-inch hazardous liquid pipeline system designated as the Sterling III Pipeline contains an apparent condition that, without corrective measures, could pose a pipeline integrity risk to public safety, property, or the environment. No accident or release from the Sterling III Pipeline was alleged to have occurred. Specifically, the Notice alleged that onsite inspections of the Sterling III Pipeline by PHMSA in March 2016 identified a risk condition involving the aboveground station piping on the discharge piping of several of the pumping stations. Respondent had taken mitigative steps to address mechanical vibration resulting from Variable Frequency Drive pumping units. On June 13, 2016, Respondent responded to the Notice by submitting a timely written response and request for an informal consultation. An informal consultation was held between representatives from Respondent and PHMSA wherein the Parties engaged in good faith negotiations to address the alleged risk condition according to the provisions of 49 C.F.R. § 190.239(b)(2). PHMSA subsequently provided written notification to Respondent on May 9, 2017 of the intent to conclude the informal consultation effective May 19, 2017. On May 30, 2017, Respondent submitted a timely written request for a hearing. Respondent proceeded with non-destructive examination (NDE) of three of the most frequently operated stations on the Sterling III Pipeline and in August 2017, commenced the testing. The Presiding Official made a determination to delay scheduling of a hearing to allow the Parties an opportunity to reach agreement on the scope of future NDE.#

420165014S_Consent Agreement and Order_12132019_text.pdf, page 3CPF No. 4-2016-5014S Page 2 Having agreed that settlement of this proceeding will avoid further administrative proceedings or litigation and that entry of this Consent Agreement and Order (Agreement and Order) is the most appropriate means of resolving the Notice, pursuant to 49 C.F.R. Part 190, without adjudication of any issue of fact or law, and upon consent and agreement of Respondent and PHMSA (the Parties), the Parties agree as follows: I. General Provisions 1. Respondent acknowledges that the Sterling III Pipeline is regulated by PHMSA, and, therefore, as the operator, Respondent is 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 Agreement and Order, Respondent further 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 administrative orders issued thereunder. 2. Respondent neither admits nor denies any allegation or conclusion in the Notice but agrees, for the purposes of this Agreement and Order, to address the alleged risk condition on the Sterling III Pipeline by completing the actions specified in Article II of this Agreement and Order (Corrective Measures), as well as to abide by the terms of this Agreement and Order. This Agreement and Order does not constitute a finding of violation of any Federal law or regulation and may not be used in any civil or administrative proceeding of any kind as evidence or proof of any fact, fault or liability, or as evidence of the violation of any law, rule, regulation or requirement, except in a proceeding to enforce the provisions of this Agreement and Order. 3. Respondent consents to the issuance of this Agreement and Order, and hereby waives any further procedural requirements with respect to its issuance. Subject to the rights granted by Section 20 hereof, Respondent waives all rights to contest the adequacy of notice, or the validity of this Agreement and Order, including all rights to administrative or judicial hearings, reviews, or appeals. 4. This Agreement and Order 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 Order and any incorporated work plans and schedules to such of Respondent’s officers, employees, and agents whose duties might reasonably include compliance with this Agreement and Order. 5. For any transfer of ownership or operating responsibility of Respondent’s Sterling III Pipeline occurring during the term of this Agreement and Order, Respondent will provide a copy of this document to the prospective transferee at least 30 days prior to such transfer. Respondent shall provide written notice of the actual transfer to the Director,#

420165014S_Consent Agreement and Order_12132019_text.pdf, page 4CPF No. 4-2016-5014S Page 3 PHMSA Southwest Region (Director) not later than 60 days following the consummation of any such transfer. 6. This Agreement and Order constitutes the final, complete and exclusive agreement and understanding between the Parties with respect to the settlement embodied herein. The Parties acknowledge that no representations, agreements, or understandings relate to this settlement other than those expressly contained in this Agreement and Order, except that the terms of this Agreement and Order may be construed by reference to the Notice. 7. Nothing in this Agreement and Order 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 administrative orders issued thereunder. Nothing in this Agreement and Order alters PHMSA’s right of access, entry, inspection, and information gathering, or PHMSA’s authority to bring enforcement action(s) against Respondent pursuant to the Federal pipeline safety laws, the regulations and orders issued thereunder, or any other provision of Federal law, including future enforcement action relating to Respondent’s Sterling III Pipeline. 8. This Agreement and Order does not waive or modify any law or regulation applicable to Respondent’s Sterling III Pipeline. This Agreement and Order is not a permit, or a modification of any permit, under any laws or regulations. Respondent remains responsible for maintaining compliance with all applicable laws, regulations and permits. 9. This Agreement and Order does not create rights in, or grant any cause of action to, any third party not party to this Agreement and Order. U.S. Department of Transportation and PHMSA are 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 and Order. Respondent agrees to indemnify and 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 the work required by this Agreement and Order. 10. This Agreement and Order resolves the underlying issues in the Notice. This Agreement and Order makes no findings of violation. The terms of this Agreement and Order constitute an offer of settlement until executed by the Associate Administrator for Pipeline Safety. Upon execution of this Agreement and Order by both Parties, any request for a hearing submitted by Respondent shall be automatically withdrawn. 11. Upon the issuance of this Agreement and Order, Respondent agrees to perform the Corrective Measures set forth in Article II below. These actions, including any work plans and schedules, are automatically incorporated into this Agreement and Order. Any work plans and schedules will be revised, as mutually determined to be necessary, to incorporate new information obtained during the activities performed.#

420165014S_Consent Agreement and Order_12132019_text.pdf, page 5CPF No. 4-2016-5014S Page 4 Respondent will submit any such plan revisions to the Director for prior approval in accordance with Section 18. II. Corrective Measures 12. Item 1. Vibration Study. Respondent will perform a comprehensive study to determine the specific circumstances and conditions in which potentially damaging vibrational effects may occur during the operation of the Sterling III pipeline system. This will include, but is not limited to, the determination of the specific locations most susceptible to damage, data collection at locations most susceptible to vibrational damage, and identification of welds, piping and piping components most susceptible to damage. This study will be completed and submitted to the Director within 60 days from the Effective Date of this Agreement. 13. Item 2. Remedial Work Plan. Upon completing the vibration study under Item 1, Respondent will develop and submit to the Director for review and approval a remedial work plan (RWP) to mitigate the effects of damaging vibration to its pipeline. The RWP may include, but is not limited to, piping reconfigurations, limits on operating ranges, vibration dampeners, inline vibrational dampening devices, or a combination of such mitigative measures. For the proposed mitigative measures, ONEOK must demonstrate, in the form of vibration test data, the effectiveness in preventing damaging vibration. The RWP will be submitted to the Director within 60 days of completion of the vibration study. Respondent will perform the actions in the RWP, as approved by the Director within 180 days of approval. 14. Item 3. Engineering Solutions. Within 90 days of the Effective Date of this Agreement, ONEOK must prepare and submit to the Director written procedures for designing any new or modified pump stations to mitigate the risk of damage due to vibration. The written procedures, upon approval by the Director, must be incorporated into ONEOK’s manual of written procedures for Operations and Maintenance (O&M) and must be followed for each new or modified pump station to mitigate the risk of damage from vibration. The design procedures must be tested and validated in the same manner as provided in Item 2. 15. Documentation. Respondent shall retain on file documentation of compliance with the provisions of Sections 12, 13, and 14 hereof. Respondent shall provide copies of such documentation to the Director upon written request. 16. Quarterly Reporting. Until termination pursuant to the provisions of Section 26 hereof, Respondent must submit quarterly reports to the Director, due not more than 30 days following the end of each calendar quarter, describing the progress of the Corrective Measures being undertaken pursuant to Sections 12, 13, and 14 hereof. 17. Documentation of Costs. It is requested (not mandated) that Respondent maintain documentation of the safety improvement costs associated with fulfilling this#

420165014S_Consent Agreement and Order_12132019_text.pdf, page 6CPF No. 4-2016-5014S Page 5 Agreement and Order and submit the total to the 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. III. Approvals 18. With respect to the submissions under this Agreement and Order requiring the approval of the Director, the Director shall act promptly to: (a) approve, in whole or part, the submission; (b) approve the submission on specific conditions; (c) disapprove, in whole or in part, the submission, directing that Respondent modify the submission; or (d) any combination of the above. In the event of approval, approval in part, or approval upon conditions, Respondent will proceed to take all action required by the submission, as approved or conditioned by the Director, subject to Respondent’s right to invoke the dispute resolution procedures in Section 20 with respect to any conditions specified by the Director. If the Director conditions or disapproves all or any portion of a submission, the Director will in writing state with specificity the basis for the decision and Respondent will resubmit it to address the stated issues. If a resubmitted item is disapproved in whole or in part, the Director may again require Respondent to address the stated issues in accordance with the foregoing procedure, or Respondent may proceed to dispute resolution pursuant to Section 20 below. IV. Extensions of Time 19. The Director may grant an extension of time for compliance with any of the terms of this Agreement and Order upon a written request submitted at least 15 calendar days prior to a stated deadline, demonstrating good cause for an extension. The Director shall respond within a reasonable time to any such request for extension of time. V. Dispute Resolution 20. The Director and Respondent will attempt to resolve informally any disputes arising under this Agreement and Order, including but not limited to any decision of the Director. The Director and Respondent will first confer in an effort to resolve any dispute. If the Director and Respondent are unable to resolve informally the dispute within 15 business days of notice by Respondent, Respondent may request in writing, within 10 business days of the end of said 15-day period, a written determination resolving the dispute by the PHMSA Associate Administrator for Pipeline Safety. Along with its request, Respondent will provide the Associate Administrator with all information Respondent believes is relevant to the dispute. If the request is submitted as provided herein, the Associate Administrator will promptly issue a written determination that will constitute final agency action, and be subject to judicial appeal. The existence of a dispute and PHMSA’s consideration of matters placed in dispute shall not excuse, toll, or suspend any term or timeframe for completion of any Corrective Measures to be performed under#

420165014S_Consent Agreement and Order_12132019_text.pdf, page 7CPF No. 4-2016-5014S Page 6 this Agreement and Order during the pendency of the dispute resolution process, except as agreed by the Director or the Associate Administrator in writing. VI. Enforcement 21. Respondent’s obligations pursuant to this Agreement and Order may be enforced by PHMSA pursuant to enforcement authorities available to PHMSA under 49 U.S.C. § 60101, et seq., and 49 C.F.R. Part 190. All deadlines set forth or referenced in this Agreement and Order will be automatically incorporated into this Agreement and Order and, subject to Respondent’s right to request an extension of time under Section 19 and modify this Agreement under Section 25, are enforceable in the same manner. VII. Recordkeeping and Information Disclosure 22. Except as otherwise provided herein, Respondent agrees to maintain records demonstrating compliance with all requirements of this Agreement and Order for a period of five years following notice by Respondent of the completion of all work to be performed. 23. For any reports, plans, or other deliverables required to be submitted to PHMSA pursuant to this Agreement and Order, 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 and Order in accordance with 49 C.F.R. Part 7 and 49 C.F.R. § 190.343. 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 will determine the release of any information submitted pursuant to this Agreement and Order 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 statutes, regulations and Executive Orders. VIII. Effective Date 24. The term “Effective Date,” as used herein, is the later date on which this Agreement and Order is fully executed by each of the Parties. Unless specified to the contrary, all deadlines for actions required by this Agreement and Order run from the Effective Date. IX. Modification 25. The terms of this Agreement and Order may be modified by mutual agreement of the Parties. Such modifications must be in writing and signed by both Parties.#

420165014S_Consent Agreement and Order_12132019_text.pdf, page 8CPF No. 4-2016-5014S Page 7 X. Termination 26. This Agreement and Order terminates upon completion of all actions set forth in Article II, as determined by the Director. Respondent may request written confirmation from PHMSA when this Agreement and Order is terminated, in which case the Director will provide such written confirmation within a reasonable time. Nothing in this Agreement and Order prevents Respondent from completing any of the obligations earlier than the deadlines provided for in this Agreement and Order. XI. Ratification 27. The Parties’ undersigned representatives certify that they are fully authorized to enter into the terms and conditions of this Agreement and Order and to execute and legally bind such party to this document. 28. The Parties hereby agree to all conditions and terms of this Agreement and Order. For Respondent: ___________________________________ Scott Schingen Vice President, Natural Gas Liquids Operations ONEOK NGL Pipeline, L.L.C. December 10, 2019 ________________________ Date For PHMSA: ___________________________________ Alan K. Mayberry Associate Administrator for Pipeline Safety Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation December 12, 2019 ________________________ Date#

420165014S_Notice of Proposed Safety Order_05162016_text.pdf, page 1Official PDFCERTIFIED MAIL - RETURN RECEIPT REQUESTED May 16, 2016 Mr. Wes Christensen Vice President NGL Operations ONEOK NGL Pipeline, LLC 100 West Fifth Street Tulsa, OK 74102 CPF 4-2016-5014S Dear Mr. Christensen: Enclosed is a Notice of Proposed Safety Order (Notice) issued in the above-referenced case. The Notice proposes that you take certain measures with respect to your Sterling III Pipeline in Oklahoma and Texas to ensure pipeline safety. Your options for responding are set forth in the Notice. Your receipt of the Notice constitutes service of that document under 49 C.F.R. §190.5. We look forward to a successful resolution to ensure pipeline safety. Please direct any questions on this matter to me at (713) 272-2852. Sincerely, R. M. Seeley Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosures: Notice of Proposed Safety Order and Copy of 49 CFR §190.239#

420165014S_Notice of Proposed Safety Order_05162016_text.pdf, page 2DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY Southwest Region Houston, TX 77074 ___________________________________ ) In the Matter of ) ) ONEOK NGL Pipeline, LLC ) CPF 4-2016-5014S ) Respondent ) ___________________________________ ) NOTICE OF PROPOSED SAFETY ORDER Background and Purpose Beginning on May 18, 2015, pursuant to 49 U.S.C. § 60117, the Pipeline and Hazardous Materials Safety Administration (PHMSA) initiated an on-site Initial Operating Inspection (IOI) of the safety of the Sterling III Pipeline (Sterling III) facilities located in Oklahoma and Texas operated by ONEOK NGL Pipeline, LLC (ONEOK, the Operator). As a result of the ongoing inspection, it appears that conditions exist on the Sterling III facilities that pose a pipeline integrity risk to public safety, property or the environment. Pursuant to 49 U.S.C. §60117(l), PHMSA issues this Notice of Proposed Safety Order (Notice), notifying you of the preliminary findings of the inspection, and proposing that you take measures to ensure that the public, property, and the environment are protected from the potential risk. Preliminary Findings • ONEOK has owned and operated Sterling III since completing construction and commissioning it in 2013. The Sterling III is consists 550 miles of 16-inch pipeline and 15 pump stations from Medford, OK to Mont Belvieu, TX. The pipeline is designed to transport a HVL (propane mix). The pump stations are Medford III, Lucien, Luther, Tecumseh, Latta, Blue River, Bells, Caddo Mills, Van Zandt, Poyner III, Salmon III, Groveton III, Goodrich, Cleveland III, and OMBS III. • During PHMSA’s field inspection of the ONEOK Sterling III Pipeline, makeshift appurtenances were observed by inspectors attached to the aboveground station piping on the discharge piping of several of the pumping stations. The makeshift appurtenances were placed in numerous locations on aboveground piping, downstream of the pumping equipment. The appurtenances consisted of a short section of structural steel balanced across the top of a branch pipe with attached fabric straps going underneath the piping.#

420165014S_Notice of Proposed Safety Order_05162016_text.pdf, page 32 • Upon PHMSA’s observation of the makeshift appurtenances, Operator personnel accompanying the field inspection were asked to explain the nature and purpose of the makeshift appurtenances. The following information was acquired from the Operator: o The Variable Frequency Drive (VFD) pumps generated and conducted severe mechanical vibration into the station piping during some operating conditions. o The vibrations from the VFD pumps are suspected by the Operator to have caused cracks in welds on pump discharge piping on other ONEOK pipeline systems. Some of these cracks resulted in failures of the welds and release of commodity in other systems. o The makeshift appurtenances were temporary devices installed in attempt to reduce the vibration of the piping and prevent failures on the Sterling III pipeline due to weld cracking, which had been experienced on other ONEOK pipelines. • The Sterling III Pipeline pump stations and station piping affected by the vibration issue include thirteen locations. The locations and number of pump units include the following: Medford III (three pumps), Lucien (two pumps), Tecumseh (two pumps), Latta (one pump), Blue River (one pump), Bells (one pump), Caddo Mills (one pump), Van Zandt (one pump), Poyner III (one pump), Salmon III (one pump), Groveton III (one pump), Goodrich (two pumps), and OMBS III (two pumps). • At the time of the Sterling III inspection, ONEOK could not provide procedures for the installation of the makeshift appurtenances that PHMSA had requested. ONEOK was also not able to produce Operator Qualification procedures for installing the devices on a Part 195 regulated pipeline, or definitive engineering analyses that showed the makeshift appurtenances, or a more permanent version of the appurtenances, reduced the threat of failure. Subsequent to the field inspection where PHMSA requested an installation procedure, ONEOK sent PHMSA a document they represented as a procedure for installing the makeshift appurtenances. The document did not adequately cover the installation requirements, had no identification showing it was a ONEOK procedure, no revision date, and there was no indication that it had been incorporated into ONEOK’s procedures using their Management of Change process. • At the time of the PHMSA Sterling III inspection, the Operator could not confirm that operating restrictions had been implemented to reduce the threat of failure until the risk caused by the vibrations had been mitigated. ONEOK had not made any pressure reductions or filed any safety-related condition reports pertaining to this issue. The seriousness of the threat and urgency of implementing preventative measures is not reflected in the actions being taken by ONEOK. • The only information provided by ONEOK based on PHMSA’s request for analyses showing the effectiveness of the makeshift appurtenances or recommendations for a permanent solution were in the form of PowerPoint presentations or very brief reports authored by IVC Technologies of Houston, TX. The IVC documents confirm the severity of the vibration issue but offer no confirmation that the makeshift appurtenances or more permanent bracing will fully mitigate the threat. The solution that IVC indicates will remove 99% of the vibration is not being implemented by ONEOK. These analyses did not include any nondestructive examination of the welds to determine if the vibration had#

420165014S_Notice of Proposed Safety Order_05162016_text.pdf, page 43 already caused cracking in the welds. These documents also show that ONEOK knew about this vibration issue on other parts of their pipeline system as far back as August 2015 on the ONEOK Arbuckle Pipeline. Given the integrity threat posed by the vibration issue on the ONEOK Sterling III Pipeline, PHMSA requested all engineering analyses pertaining to this issue, the failure investigations or root cause analyses performed, a complete explanation of the preventative and mitigative measures being taken by ONEOK, and how the threat had been incorporated into their Integrity Management Plan. The Operator did not provide an adequate response to this request. Proposed Issuance of Safety Order Section 60117(l) of Title 49, United States Code, provides for the issuance of a safety order, after reasonable notice and the opportunity for a hearing, requiring corrective measures, which may include physical inspection, testing, repair, or other action, as appropriate. The basis for making the determination that a pipeline facility has a condition or conditions that pose a pipeline integrity risk to public safety, property, or the environment is set forth both in the above-referenced statute and 49 CFR §190.239, a copy of which is enclosed. After evaluating the foregoing preliminary findings of fact and considering the hazardous nature of the product transported, the pressure required for transporting such product, the characteristics of the geographical areas where the pipeline facility is located, the absence of a conclusive determination that the dampening methods used by ONEOK are sufficient to maintain the integrity of the pipeline, instances of cracking failures resulting in unplanned releases of products in pipeline systems operated by ONEOK with similar vibrational issues, and the potential that conditions could worsen or develop on other areas of the pipeline and potentially impact its serviceability, it appears that continued operation of the affected pipeline, without corrective measures, would pose a pipeline integrity risk to public safety, property, or the environment. Accordingly, PHMSA issues this Notice of Proposed Safety Order to notify Respondent of the proposed issuance of a safety order and to propose that Respondent take the measures specified herein to address the potential risk. Response to this Notice In accordance with §190.239, you have 30 days following receipt of this Notice to submit a written response to the official who issued the Notice. If you do not respond within 30 days, this constitutes a waiver of your right to contest 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 safety order. In your response, you may notify that official that you intend to comply with the terms of the Notice as proposed, or you may request that an informal consultation be scheduled (you will also have the opportunity to request an administrative hearing before a safety order is issued). Informal consultation provides you with the opportunity to explain the circumstances associated with the risk condition(s) alleged in the Notice and, as appropriate, to present a proposal for a work plan or other remedial measures, without prejudice to your position in any subsequent hearing. If you and PHMSA agree within 30 days of informal consultation on a plan and schedule for you to address each identified risk condition, we may enter into a written consent agreement (PHMSA would then issue an administrative consent order incorporating the terms of the agreement). If a consent agreement#

420165014S_Notice of Proposed Safety Order_05162016_text.pdf, page 54 is not reached, or if you have elected not to request informal consultation, you may request an administrative hearing in writing within 30 days following receipt of this Notice or within 10 days following the conclusion of an informal consultation that did not result in a consent agreement, as applicable. Following a hearing, if the Associate Administrator finds the facility to have a condition that poses a pipeline integrity risk to the public, property, or the environment in accordance with §190.239, the Associate Administrator may issue a safety order. 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). In your correspondence on this matter, please refer to CPF 4-2016-5014S for each document you submit, please provide a copy in electronic format whenever possible. Proposed Corrective Measures Pursuant to 49 U.S.C. §60117(l) and 49 C.F.R. §190.239, PHMSA proposes to issue to ONEOK NGL Pipeline, LLC a Safety Order (Order) incorporating the following remedial requirements with respect to its Sterling III Pipeline located in Oklahoma and Texas: 1. ONEOK must make, at a minimum, an immediate 20% pressure reduction on their Sterling III Pipeline as required by §195.55 and implement operational constraints on the pump units to reduce the vibration and threat of failure. The pressure reduction and operational constraints must remain in place until approval to resume normal operations is given by the PHMSA Southwest Region Director. 2. Within 30 days of receipt of the Order, ONEOK must submit to the PHMSA Southwest Region Director, a complete plan of inspection to determine the full extent of damage caused by the vibration. The plan must be submitted to the Southwest Region Director for approval prior to initiation. The plan, at a minimum, must include nondestructive examination of all piping and welds at the pumps stations by an independent third party using technology adequate to detect any defects and integrity threats resulting from the vibrations. These inspections would begin immediately following the Director’s approval with a weekly written report of findings submitted to the Southwest Region Director at the same time the report is submitted to ONEOK. The Operator’s proposed choice of the independent third party must also be submitted to the PHMSA Southwest Region Director for approval prior to the commencement of work. 3. The operator must immediately inform the PHMSA Southwest Region Director of any integrity threatening defects found by the inspection in Item 2. The Operator must also inform the PHMSA Southwest Region Director of the repair plans and justify the method of repair and timing based on the specific defect(s) in writing. The information provided to PHMSA must include details about the type, size, and location of the defect, the proposed repair method, and the timing of the repair.#

420165014S_Notice of Proposed Safety Order_05162016_text.pdf, page 65 4. Within 30 days of receipt of the Order, ONEOK must submit a plan to the PHMSA Southwest Region Director for approval, to perform a complete, systematic analysis of the vibration problem, determine the specific operational conditions where the vibration occurs, and propose mitigation measures to prevent damage to the pipeline from the vibrations. The proposed plan must be performed by an independent third party, including a means to verify the effectiveness of the mitigation measures, and perform periodic monitoring of the effectiveness after the mitigation measures are implemented. The independent third party must also be approved by the PHMSA Southwest Region Director prior to the commencement of work. 5. Based on the results of Item 4, ONEOK must submit to the PHMSA Southwest Region Director a written plan and schedule to implement the specific measures selected by the Operator to mitigate the integrity threat caused by the vibration. The plan must be approved by the PHMSA Southwest Region Director prior to the commencement of work. The plan may propose a limited implementation followed by monitoring and testing to ensure the effectiveness of the measures. However, ONEOK must complete testing and implementation of the selected mitigative measures at all affected locations within one year of the Order. If a limited implementation is first proposed to confirm the effectiveness, subsequent required implementation plans must be submitted to the Southwest Region for approval within 30 days after the confirmation period. 6. The Director may grant an extension of time for compliance with any of the terms of the Safety Order upon a written request timely submitted demonstrating good cause for an extension. 7. ONEOK may appeal any decision of the Director to the Associate Administrator for Pipeline Safety. Decisions of the Associate Administrator shall be final. The actions proposed by this Notice of Proposed Safety Order are in addition to and do not waive any requirements that apply to Respondent’s pipeline system under 49 C.F.R. Parts 190 through 199, under any other order issued to Respondent under authority of 49 U.S.C. § 60101 et seq., or under any other provision of Federal or state law. After receiving and analyzing additional data in the course of this proceeding and implementation of the work plan, PHMSA may identify other safety measures that need to be taken. In that event, Respondent will be notified of any proposed additional measures and, if necessary, amendments to the work plan or Safety Order. ________________________________ __________________ R. M. Seeley Date issued Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#

420165014S_Closure Letter_04122022_(16-153426S)_text.pdf, page 1Official PDFELECTRONIC MAIL - RETURN RECEIPT REQUESTED April 12, 2022 Walter L. Allen Vice President, Natural Gas Liquids Operations ONEOK NGL Pipeline, L.L.C. 100 West Fifth Street Tulsa, Oklahoma 74103 CPF 4-2016-5014S Dear Mr. Allen: On May 16, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), issued a Notice of Proposed Safety Order (Notice) to ONEOK NGL Pipeline, L.L.C (ONEOK). The Notice alleged that PHMSA’s onsite inspetions of the Sterling III Pipeline identified a risk condition with the aboveground pumping stations involving the discharge piping subject to mechanical vibration resulting from Variable Frequency Drive Units. On December 13, 2019, PHMSA and ONEOK entered into a Consent Agreement and Order to resolve the issues underlying the Notice. Over the past two years, PHMSA and ONEOK representatives have met to discuss the actions taken to comply with the provisions of the Consent Agreement and have reached consensus on the substantial resolution of the three items contained in the Consent Agreement. On February 16, 2022, ONEOK submitted a request for closure in accordance with Section 26 of the Consent Agreement. PHMSA staff reviewed the responses provided to demonstrate compliance with the Consent Agreement and determined that ONEOK has substantially complied with the terms of the Agreement. This letter is to inform you no further responses in this case are required, and this case is now closed. Thank you for your cooperation. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration#