{"operation":"document","citation":"CPF 420175031M","title":"ONEOK NGL PIPELINE, LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2017-08-24","effective_on":null,"summary":"CLOSED notice of amendment citing 195.444, 195.446(b), 195.446(c)(1), 195.446(c)(4), 195.446(d)(1), 195.446(d)(4).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175031m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175031m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420175031m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420175031M","body":"Notice of Amendment involving ONEOK NGL PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.444,  195.446(b),  195.446(c)(1),  195.446(c)(4),  195.446(d)(1),  195.446(d)(4). The case was opened on 2017-08-24 and is reported as closed as of 2017-11-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420175031M_Closure Letter_11272017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175031M/420175031M_Closure%20Letter_11272017.pdf\n\n420175031M_Closure Letter_11272017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175031M/420175031M_Closure%20Letter_11272017_text.pdf\n\n420175031M_Notice of Amendment_08242017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175031M/420175031M_Notice%20of%20Amendment_08242017.pdf\n\n420175031M_Notice of Amendment_08242017_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175031M/420175031M_Notice%20of%20Amendment_08242017_text.pdf\n\n420175031M_Operator Response to Notice_10042017.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420175031M/420175031M_Operator%20Response%20to%20Notice_10042017.pdf\n\n420175031M_Notice of Amendment_08242017_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 24, 2017\nONEOK NGL PIPELINE, LLC\nMr. Roger Thorpe - VP NGL Operations\n100 WEST FIFTH STREET\nTulsa, OK 74102\nCPF 4-2017-5031M\nDear Mr. Thorpe:\nOn May 23-27, 2016, representatives of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected ONEOK\nNGL PIPLEINE, LLC (ONEOK) procedures for Control Room Management (CRM) Plan and\nrecords in Tulsa, Oklahoma.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nONEOK’s plans or procedures, as described below:\n1. §195.446 Control room management\n(b) Roles and responsibilities. Each operator must define the roles and responsibilities\nof a controller during normal, abnormal, and emergency operating conditions.\nONEOK’s Controllers Physical Domain of Responsibility, last revised October 23, 2015, Scope\nstates “Provide the Pipeline Controllers with a defined domain of responsibility for the pipeline\nsystem’s physical assets and facilities per Console as well as who may assume control of any\nconsole. Intent also aims to comply with 195.446(b)(1) as the operator should clearly establish\neach controller’s roles and domain of responsibility when more than one controller is on shift”.\n\n\n\nDuring the inspection, ONEOK informed the PHMSA Inspectors that it is not a periodic\noccurrence and any changes to Roles and Responsibility would be handled by Management of\nChange (MOC).\nWhen the PHMSA inspector reviewed ONEOK’s MOC process, last revised October 20, 2015,\nthis activity is not required.\nONEOK must amend their MOC process to include this activity.\n2. §195.446 Control room management\n(c) Provide adequate information. Each operator must provide its controllers with the\ninformation, tools, processes and procedures necessary for the controllers to carry\nout the roles and responsibilities the operator has defined by performing each of the\nfollowing:\n(1) Implement API RP 1165 (incorporated by reference, see §195.3) whenever a\nSCADA system is added, expanded or replaced, unless the operator demonstrates\nthat certain provisions of API RP 1165 are not practical for the SCADA system used;\nONEOK’s CRM plan, OKSPCC2.0001, Section 4.3: ADEQUATE INFORMATION (192.631(C);\n195.446(C)) states “Implement applicable sections of API RP 1165 whenever a SCADA system\nis added, expanded or replaced (all sections of API RP 1165 for hazardous liquid pipeline systems).\nONEOK did not include specific procedures to clarify which additions or expansions will require\nAPI RP1165 implementation. For example, the addition of a new pipeline system to the new\nSCADA system did not meet their definition of system expansion.\nONEOK must amend this process to define the types of changes to the SCADA system that\nconstitute additions, expansions, or replacements.\n3. §195.446 Control room management\n(c) Provide adequate information. Each operator must provide its controllers with the\ninformation, tools, processes and procedures necessary for the controllers to carry\nout the roles and responsibilities the operator has defined by performing each of the\nfollowing:\n(4) Test any backup SCADA systems at least once each calendar year, but at intervals\nnot to exceed 15 months\n2\n\n\n\nDuring the inspection, ONEOK representatives advised the PHMSA inspectors that ONEOK does\nnot use a backup system for development. ONEOK has a secured test SCADA system that includes\na primary and a backup SCADA server running as a HA (High Availability) pair. This system is\nisolated from the production system by isolation in a different subnet. The system is used for\ntesting changes and Microsoft Windows patches prior to updating the production system.\nThe PHMSA inspector did not find this documented under ONEOK’s CRM plan.\nONEOK must amend their Control Room Plan to add this information.\n4. §195.446 Control room management\n(d) Fatigue mitigation. Each operator must implement the following methods to\nreduce the risk associated with controller fatigue that could inhibit a controller's\nability to carry out the roles and responsibilities the operator has defined:\n(1) Establish shift lengths and schedule rotations that provide controllers off-duty\ntime sufficient to achieve eight hours of continuous sleep.\nDuring the inspection, the PHMSA inspector learned that controllers are not on-call. Supervisors\nare salaried/on-call but are held to the same Hours of Service (HOS) limitations. This is not\ndocumented in ONEOK CRM plan. Also, the same plan failed to indicate that supervisors will not\napprove their own HOS deviations.\nONEOK must amend CRM plan to add this.\n5. §195.446 Control room management\n(d) Fatigue mitigation. Each operator must implement the following methods to\nreduce the risk associated with controller fatigue that could inhibit a controller's\nability to carry out the roles and responsibilities the operator has defined:\n(4) Establish a maximum limit on controller hours-of-service, which may provide for\nan emergency deviation from the maximum limit if necessary for the safe operation\nof a pipeline facility.\n3\n\n\n\nONEOK CRM Fatigue Management, last revised date 9-8-2015 states “The shift holdover\nguideline limits are no more than, one 18-hour shift (19 hours with handover time), or two 14 hours\nshifts (15 hours with handover time) in any sliding 5-day period.\nFor a 12-hour shift, a one 18-hour shift (19 hours with hand-over time) in any sliding 5-day period\nduring non-emergency situation does not meet the requirement of this section of the code. ONEOK\nmust amend their procedure to remove 18-hour shift.\n6. §195.444 CPM leak detection.\nEach computational pipeline monitoring (CPM) leak detection system installed on a\nhazardous liquid pipeline transporting liquid in single phase (without gas in the\nliquid) must comply with API RP 1130 (incorporated by reference, see §195.3) in\noperating, maintaining, testing, record keeping, and dispatcher training of the\nsystem.\nONEOK implemented computational pipeline monitoring (CPM) to their pipelines in 2005.\nONEOK’s CPM testing process is in draft form and does not currently address API 1130. ONEOK\nhas been using Energy Solutions, Site Acceptance Test procedures which conform with the\napplicable element of API 1130, though not specifically mentioned. According to ONEOK, the\nCPM system complies with operating, maintaining, testing, and maintenance as\nrecommended. However, the operator is working on improving the record-keeping aspect of the\ntests.\nONEOK must assure its CPM process meets the requirement of API 1130.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of this Notice,\nthis constitutes a waiver of your right to contest the allegations in this Notice and authorizes the\nAssociate Administrator for Pipeline Safety to find facts as alleged in this Notice without further\nnotice to you and to issue a Final Order.\n4\n\n\n\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this\nNotice, you may be ordered to amend your plans or procedures to correct the inadequacies (49\nC.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 60 days of receipt of this Notice. This period may be extended by\nwritten request for good cause. Once the inadequacies identified herein have been addressed in\nyour amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that ONEOK NGL PIPLEINE, LLC maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to R. Seeley, Director, Southwest,\nPipeline and Hazardous Materials Safety Administration. In correspondence concerning this\nmatter, please refer to CPF 4-2017-5031M and, for each document you submit, please provide a\ncopy in electronic format whenever possible.\nSincerely,\nFrank Causey\nActing Director, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n5\n\n420175031M_Closure Letter_11272017_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 27, 2017\nONEOK NGL PIPELINE, L.P\nMr. Roger Thorpe - VP NGL Operations\n100 WEST FIFTH STREET\nTulsa, OK 74102\nCPF 4-2017-5031M\nDear Mr. Thorpe:\nOn August 25, 2017, the Pipeline and Hazardous Materials Safety Administration issued to\nONEOK NGL PIPLEINE, L.P (ONEOK), a Notice of Amendment which proposed amendment\nof your Control Room Management procedures.\nONEOK submitted its amended procedures on October 4 and November 6, 2017. My staff\nreviewed the amended procedures, and it appears that inadequacies outlined in this Notice of\nAmendment have been corrected.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nFrank Causey\nActing Director, Southwest Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":11153}