# ONEOK NGL PIPELINE, LLC — Safety Order

- **operation:** document
- **citation:** CPF 420165014S
- **title:** ONEOK NGL PIPELINE, LLC — Safety Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2016-05-16
- **effective on:** Not available
- **summary:** CLOSED safety order.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-420165014s.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-420165014s
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/420165014S
**body:**

Safety Order involving ONEOK NGL PIPELINE, LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2016-05-16 and is reported as closed as of 2022-04-18. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

420165014S_Closure Letter_04122022_(16-153426S).pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165014S/420165014S_Closure%20Letter_04122022_(16-153426S).pdf

420165014S_Closure Letter_04122022_(16-153426S)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165014S/420165014S_Closure%20Letter_04122022_(16-153426S)_text.pdf

420165014S_Consent Agreement and Order_12132019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165014S/420165014S_Consent%20Agreement%20and%20Order_12132019.pdf

420165014S_Consent Agreement and Order_12132019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165014S/420165014S_Consent%20Agreement%20and%20Order_12132019_text.pdf

420165014S_Notice of Proposed Safety Order_05162016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165014S/420165014S_Notice%20of%20Proposed%20Safety%20Order_05162016.pdf

420165014S_Notice of Proposed Safety Order_05162016_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165014S/420165014S_Notice%20of%20Proposed%20Safety%20Order_05162016_text.pdf

420165014S_Operator Request for Hearing_05302017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165014S/420165014S_Operator%20Request%20for%20Hearing_05302017.pdf

420165014S_Operator Response to Notice_08242016.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420165014S/420165014S_Operator%20Response%20to%20Notice_08242016.pdf

420165014S_Consent Agreement and Order_12132019_text.pdf

December 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



U.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.



CPF 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,



CPF 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.



CPF 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



CPF 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



CPF 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.



CPF 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

CERTIFIED 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



DEPARTMENT 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.



2
• 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



3
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



4
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.



5
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

ELECTRONIC 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
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