ONEOK NGL PIPELINE, LLC — Warning Letter

420175030W_Warning Letter_08242017_text.pdf, page 1Official PDFWARNING LETTER CERTIFIED MAIL - RETURN RECEIPT REQUESTED August 24, 2017 ONEOK NGL PIPELINE, LLC Mr. Roger Thorpe - VP NGL Operations 100 WEST FIFTH STREET Tulsa, OK 74102 CPF 4-2017-5030W Dear Mr. Thorpe: May 23-27, 2016, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected your ONEOK NGL PIPLEINE, LLC (ONEOK) Control Room in Tulsa, Oklahoma. As a result of the inspection, it appears that you have committed a probable violation of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations. The item inspected and the probable violation is: 1. §195.505 Qualification program Each operator shall have and follow a written qualification program. The program shall include provisions to: (a) Identify covered tasks; (b) Ensure through evaluation that individuals performing covered tasks are qualified;#

420175030W_Warning Letter_08242017_text.pdf, page 2ONEOK failed to ensure through evaluation that the controller was qualified to perform covered tasks. ONEOK CRM Controller Training Program last revised on August 25, 2015, Operator Qualifications states “each controller is responsible for successfully demonstrating the ability to perform the following covered tasks: Sub-Task 64.1 Startup of a Pipeline Sub-Task 64.2 Shutdown of a Pipeline, Sub-Task 64.3 Monitor Pressures, Flow, Communications and Line integrity & Maintain Them Within Allowable Limits, and Sub-Task 64.4 Remotely Open or Close Valves or Other Equipment. Abnormal Operating Conditions are identified during these Sub-Tasks”. The PHMSA inspector also reviewed ONEOK’s NGL Operator Qualification Plan, revised July 31, 2014, Appendix A: Covered Task List, and it indicates that these tasks require re-evaluation every three (3) years. While reviewing records associated with the ONEOK shift schedule, the PHMSA inspector noted that an employee, Degroff, Tike was working at one of the Sterling Consoles during the month of November 2015. The PHMSA inspector reviewed the qualification record for this individual, and it indicated that his qualification expired on July 20, 2015. ONOK did not requalify him again until December 18, 2015. If these covered tasks are performed by a non-qualified individual, ONEOK’s OQ Plan requires a span of control of one to three. According to the shift schedule documentation for the November 2015 provided by ONEOK, a qualified employee was not observing or directing this individual at the console. Under 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000 per violation per day the violation persists up to a maximum of $2,000,000 for a related series of violations. For violations occurring prior to January 4, 2012, the maximum penalty may not exceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a related series of violations. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to correct the item identified in this letter. Failure to do so will result in ONEOK NGL PIPLEINE, LLC (ONEOK) being subject to additional enforcement action. 2#

420175030W_Warning Letter_08242017_text.pdf, page 3No reply to this letter is required. If you choose to reply, in your correspondence please refer to CPF 4-2017-5030W. 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). Sincerely, Frank Causey Acting Director, Southwest Region Pipeline and Hazardous Materials Safety Administration 3#