# ONEOK NGL PIPELINE, LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 42024025NOPV
- **title:** ONEOK NGL PIPELINE, LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2024-08-19
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 195.401(b), 195.452(g)(1), 195.452(i)(1), 195.573(e), 195.589(c).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024025nopv
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42024025NOPV
**body:**

Notice of Probable Violation involving ONEOK NGL PIPELINE, LLC. PHMSA's enforcement data identifies the cited regulations as 195.401(b),  195.452(g)(1),  195.452(i)(1),  195.573(e),  195.589(c). The case was opened on 2024-08-19 and is reported as closed as of 2025-11-25. Proposed civil penalty: $33,800. Assessed civil penalty: $31,400. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42024025NOPV_Closure Letter_11252025_(23-266077).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024025NOPV/42024025NOPV_Closure%20Letter_11252025_(23-266077).pdf

42024025NOPV_Closure Letter_11252025_(23-266077)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024025NOPV/42024025NOPV_Closure%20Letter_11252025_(23-266077)_text.pdf

42024025NOPV_Final Order_10152025_(23-266077).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024025NOPV/42024025NOPV_Final%20Order_10152025_(23-266077).pdf

42024025NOPV_Final Order_10152025_(23-266077)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024025NOPV/42024025NOPV_Final%20Order_10152025_(23-266077)_text.pdf

42024025NOPV_Operator Response to Notice_09192024_(23-266077).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024025NOPV/42024025NOPV_Operator%20Response%20to%20Notice_09192024_(23-266077).pdf

42024025NOPV_Operator Withdrawal of Hearing Request_12232024_(23-266077).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024025NOPV/42024025NOPV_Operator%20Withdrawal%20of%20Hearing%20Request_12232024_(23-266077).pdf

42024025NOPV_PCO PCP_08192024_(23-266077).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024025NOPV/42024025NOPV_PCO%20PCP_08192024_(23-266077).pdf

42024025NOPV_PCO PCP_08192024_(23-266077)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024025NOPV/42024025NOPV_PCO%20PCP_08192024_(23-266077)_text.pdf

42024025NOPV_PHC Hearing Scheduled_10172024_(23-266077).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024025NOPV/42024025NOPV_PHC%20Hearing%20Scheduled_10172024_(23-266077).pdf

42024025NOPV_PHC Hearing Scheduled_10172024_(23-266077)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024025NOPV/42024025NOPV_PHC%20Hearing%20Scheduled_10172024_(23-266077)_text.pdf

42024025NOPV_Closure Letter_11252025_(23-266077)_text.pdf

U.S. Department of Transportation
Pipeline and Hazardous Materials
Safety Administration 8701 S. Gessner, Suite 630
Houston TX 77074
VIA ELECTRONIC MAIL TO: pierce.norton@oneok.com
November 25, 2025
Pierce Norton
President and Chief Executive Officer
ONEOK NGL Pipeline, LLC
100 West Fifth Street
Tulsa, OK 74103
CPF 4-2024-025-NOPV
Dear Mr. Norton:
On October 15, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to ONEOK NGL Pipeline, LLC (ONEOK), a Final Order in the above-referenced case.
This Order included a Compliance Order and Civil Penalty assessment requirement to take
corrective actions on your pipeline. Based on our review of the documentation you provided and
confirmation of payment of the civil penalty, it has been determined that you have complied with
the terms of this Order.
This letter is to inform you that no further action is necessary, and this case is now closed. Thank
you for your cooperation.
Sincerely,
Bryan Lethcoe
Director, Southwest Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
cc: Ryan Mccoy, Regulatory Compliance Manager, ONEOK NGL Pipeline, LLC,
ryan.mccoy@oneok.com

42024025NOPV_Final Order_10152025_(23-266077)_text.pdf

October 15, 2025
VIA ELECTRONIC MAIL TO: pierce.norton@oneok.com
Pierce Norton
President and Chief Executive Officer
ONEOK NGL Pipeline, LLC
100 West Fifth Street
Tulsa, Oklahoma 74103
Re: CPF No. 4-2024-025-NOPV
Dear Mr. Norton:
Enclosed please find the Final Order issued in the above-referenced case. It withdraws one of the
allegations of violation, makes other findings of violation, assesses a civil penalty of $31,400,
and specifies actions that need to be taken by ONEOK NGL Pipeline, LLC to comply with the
pipeline safety regulations. The penalty payment terms are set forth in the Final Order. When the
civil penalty has been paid and the terms of the compliance order completed, as determined by
the Director, Southwest Region, this enforcement action will be closed. Service of the Final
Order by e-mail is effective upon the date of transmission and acknowledgement of receipt as
provided under 49 CFR § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Linda Daugherty
Acting Associate Administrator
for Pipeline Safety
Enclosure
cc: Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA
Ryan Mccoy, Regulatory Compliance Manager, ONEOK NGL Pipeline, LLC,
ryan.mccoy@oneok.com



CONFIRMATION OF RECEIPT REQUESTED



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, LLC, ) CPF No. 4-2024-025-NOPV
)
)
)
Respondent. )
____________________________________)
FINAL ORDER
From March 20 through October 26, 2023, pursuant to 49 U.S.C. § 60117, a representative of the
Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety
(OPS), conducted an on-site pipeline safety inspection of the facilities and records of ONEOK
NGL Pipeline, LLC’s (ONEOK or Respondent) natural gas liquid (NGL) pipeline facilities in
Kansas, Oklahoma, and Texas.
As a result of the inspection, the Director, Southwest Region, OPS (Director), issued to
Respondent, by letter dated August 19, 2024, a Notice of Probable Violation, Proposed Civil
Penalty, and Proposed Compliance Order (Notice). In accordance with 49 CFR § 190.207, the
Notice proposed finding that ONEOK had committed three violations of 49 CFR Part 195,
proposed assessing a civil penalty of $33,800 for the alleged violations, and proposed ordering
Respondent to take certain measures to correct the alleged violations. The Notice also included
one additional warning item pursuant to 49 CFR § 190.205, which warned Respondent to correct
the probable violation or face possible future enforcement action.
ONEOK responded to the Notice by letter dated September 19, 2024 (Response). ONEOK
contested several of the allegations and requested a hearing and informal consultation. The
parties held a virtual informal consultation on November 4, 2024 and ONEOK subsequently
provided additional materials to support its Response. By letter dated December 23, 2024,
Respondent withdrew its request for a hearing and thereby authorized the entry of this Final
Order without further notice.
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 CFR Part 195, as follows:



Item 1: The Notice alleged that Respondent violated 49 CFR § 195.452(g), which states:
§ 195.452 Pipeline integrity management in high consequence areas.
(a) . . . .
(g) What is an information analysis? In periodically evaluating the
integrity of each pipeline segment (see paragraph (j) of this section), an
operator must analyze all available information about the integrity of its
entire pipeline and the consequences of a possible failure along the pipeline.
Operators must continue to comply with the data integration elements
specified in § 195.452(g) that were in effect on October 1, 2018, until
October 1, 2022. Operators must begin to integrate all the data elements
specified in this section starting October 1, 2020, with all attributes
integrated by October 1, 2022. This analysis must:
(1) Integrate information and attributes about the pipeline that include,
but are not limited to:
The Notice alleged that Respondent violated 49 CFR § 195.452(g) by failing to analyze all
available information about the integrity of its entire pipeline and the consequences of a possible
failure along the pipeline. Specifically, the Notice alleged that ONEOK failed to integrate all the
data elements specified in this section (including: depth of cover surveys, results of examinations
of exposed portions of buried pipelines, and location of casings and if shorted) starting October
1, 2020, with all attributes integrated by October 1, 2022, for Hutch Reno Del to Hillside Booster
pipeline segment (Line ID 10374), located in Hutchinson, Kansas.
In its Response ONEOK contested Item 1, stating that its NGL Integrity Management Program,
Section 6 (Risk Analysis) was completed in accordance with 49 CFR § 195.452(g), and that all
applicable data integration elements are incorporated as variables in its risk model calculations.
ONEOK further explained that, under its Procedure 63 (Data Integration), risk model results are
integrated via Section 6 and reviewed as part of the SME Threat Category Evaluation Summary.
ONEOK stated that SME discussions of risk model results consider all integrated data elements,
including those alleged to be missing from the analysis in the Notice. ONEOK stated that this
means the Hutch Reno Del to Hillside Booster model results included depth of cover data, results
of exposed portions of buried pipelines, and casing data (including shorted casings). ONEOK
also stated that under its NGL Risk Algorithm, these data integration elements are included in the
Failure Likelihood Assessment, which evaluates susceptibility to failure from external corrosion
and third-party damage.
The parties discussed Item 1 during the informal consultation on November 4, 2024. During the
meeting, ONEOK provided additional records clarifying that its risk algorithm included the data
integration elements at issue. On December 4 and December 19, 2024, ONEOK submitted
additional information showing that it had revised its procedures to clarify that its risk model and
analysis integrate all the data elements required by § 195.452(g).
In a recommendation for final action submitted pursuant to § 190.209(b)(7), the Director
recommended withdrawing the alleged violation of § 195.452(g). Based upon the foregoing, I
hereby order that Item 1 be withdrawn.



Item 2: The Notice alleged that Respondent violated 49 CFR § 195.452(i)(1), which states:
§ 195.452 Pipeline integrity management in high consequence areas.
(a) . . . .
(i) What preventive and mitigative measures must an operator take to
protect the high consequence area? –
(1) General requirements. An operator must take measures to prevent
and mitigate the consequences of a pipeline failure that could affect a high
consequence area. These measures include conducting a risk analysis of the
pipeline segment to identify additional actions to enhance public safety or
environmental protection. Such actions may include, but are not limited to,
implementing damage prevention best practices, better monitoring of
cathodic protection where corrosion is a concern, establishing shorter
inspection intervals, installing EFRDs on the pipeline segment, modifying
the systems that monitor pressure and detect leaks, providing additional
training to personnel on response procedures, conducting drills with local
emergency responders and adopting other management controls.
The Notice alleged that Respondent violated 49 CFR § 195.452(i)(1) by failing to take measures
to prevent and mitigate the consequences of a pipeline failure that could affect a high
consequence area, including conducting a risk analysis of the pipeline segment to identify
additional actions to enhance public safety or environmental protection. Specifically, the Notice
alleged that ONEOK’s risk analysis for its Bell Pump, Frost Pump, and Hutchinson Junction
Pump Stations included incorrect information regarding internal corrosion mitigation for
facilities located in a high consequence area.
In its Response, ONEOK did not contest Item 2 as it relates to the Hutchinson Pump Station.
ONEOK stated that it had updated the Facility Risk Model for the Hutchinson Pump Station to
reflect that the evaluation questionnaire category for internal corrosion monitoring with coupon
is answered “NO,” which aligns with the actual conditions at the facility.
However, ONEOK contested Item 2 as it relates to the Bells and Frost Pump Stations. ONEOK
contended that the Facility Risk Models for both stations accurately reflect in the evaluation
questionnaire that the category for internal corrosion monitoring with coupon is answered “NO.”
Accordingly, ONEOK requested that the Bells and Frost Pump Stations be removed from this
allegation and that Item 2 be limited to the Hutchinson Pump Station.
The parties discussed this issue during the informal consultation on November 4, 2024, during
which ONEOK provided additional records demonstrating that its Facility Risk Models for the
Bells and Frost Pump Stations reflected the internal corrosion monitoring category as “NO.” On
December 31, 2024, ONEOK provided further information showing that its Facility Integrity
Database had been updated to accurately reflect the value for internal coupon corrosion
monitoring for the Hutchinson Junction Pump Station.
In a recommendation for final action dated June 3, 2025, submitted pursuant to § 190.209(b)(7),



the Director recommended withdrawing the alleged violation of § 195.452(i)(1) as it relates to
the Bells and Frost Pump Stations.
Accordingly, after considering all of the evidence, I find that Respondent violated 49 CFR
§ 195.452(i)(1) for the Hutchinson Junction Pump Station by failing to take measures to prevent
and mitigate the consequences of a pipeline failure that could affect a high consequence area,
including conducting a risk analysis of the pipeline segment to identify additional actions to
enhance public safety or environmental protection. Based upon the foregoing, Item 2 is
withdrawn as it relates to the Bells and Frost Pump Stations.
Item 4: The Notice alleged that Respondent violated 49 CFR § 195.573(e), which states:
§ 195.573 What must I do to monitor external corrosion control?
(a) . . . .
(e) Corrective action. You must correct any identified deficiency in
corrosion control as required by § 195.401(b). However, if the deficiency
involves a pipeline in an integrity management program under § 195.452,
you must correct the deficiency as required by § 195.452(h).
§ 195.401 General requirements.
(a) . . . .
(b) An operator must make repairs on its pipeline system according to
the following requirements:
(1) Non Integrity management repairs. Whenever an operator discovers
any condition that could adversely affect the safe operation of its pipeline
system, it must correct the condition within a reasonable time. However, if
the condition is of such a nature that it presents an immediate hazard to
persons or property, the operator may not operate the affected part of the
system until it has corrected the unsafe condition.
The Notice alleged that Respondent violated 49 CFR § 195.573(e) by failing to correct any
identified deficiency in corrosion control as required by §§ 195.573(e) and 195.401(b).
Specifically, the Notice alleged that, ONEOK failed to correct low cathodic protection (CP)
potential at the North Fence test point and Receiver trap test point at Warren Plant in Robert
County, Texas, for two consecutive inspection cycles
In its Response, ONEOK, did not contest Item 4, the proposed penalty, or proposed corrective
actions.
Accordingly, after considering all of the evidence, I find that Respondent violated 49 CFR
§ 195.573(e) by failing to correct any identified deficiency in corrosion control as required by
§§ 195.573(e) and 195.401(b).
These findings of violation will be considered prior offenses in any subsequent enforcement
action taken against Respondent.



ASSESSMENT OF PENALTY
Under 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty exceeding
$200,000 per violation for each day of the violation, with a maximum administrative civil
penalty exceeding $2,000,000 for any related series of violations.1
In determining the amount of a civil penalty under 49 U.S.C. § 60122 and 49 CFR § 190.225, I
must consider the following criteria: the nature, circumstances, and gravity of the violation,
including adverse impact on the environment; the degree of Respondent’s culpability; the history
of Respondent’s prior offenses; any effect that the penalty may have on its ability to continue
doing business; the good faith of Respondent in attempting to comply with the pipeline safety
regulations; and self-disclosure or actions to correct a violation prior to discovery by PHMSA.
In addition, I may consider the economic benefit gained from the violation without any reduction
because of subsequent damages, and such other matters as justice may require.
The Notice proposed a total civil penalty of $33,800 for the violation cited above. Effective May
20, 2025, PHMSA revised its proposed civil penalty calculation policy to use the version of the
Civil Penalty Worksheet in effect when the alleged violation occurred. The new policy reduces
the total proposed civil penalty in this case to $31,400.
Item 4: The Notice proposed a civil penalty of $33,800 for Respondent’s violation of 49 CFR
§ 195.573(e), for failing to correct any identified deficiency in corrosion control as required by
§§ 195.573(e) and 195.401(b). The new policy for calculating a proposed civil penalty reduces
the proposed civil penalty for this item to $31,400. ONEOK neither contested the allegation nor
presented any evidence or argument justifying a reduction of the proposed penalty. No
information was presented indicating any of the statutory civil penalty assessment factors were
incorrect or should be reduced. Therefore, I find no reason to further reduce the penalty.
In a recommendation for final action dated June 3, 2025, submitted pursuant to § 190.209(b)(7),
the Director recommended assessing the reduced civil penalty of $31,400. On June 5, 2025,
ONEOK submitted a letter agreeing with the reduced civil penalty.
Accordingly, having reviewed the record and considered the assessment criteria, I assess
Respondent a civil penalty of $31,400 for violation of 49 CFR § 195.573(e).
Payment of the civil penalty must be made within 20 days after receipt of this Final Order.
Federal regulations (49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer
through the Federal Reserve Communications System (Fedwire), to the account of the U.S.
Treasury. Detailed instructions are contained in the enclosure. Questions concerning wire
transfers should be directed to: Financial Operations Division (AMK-325), Federal Aviation
Administration, Mike Monroney Aeronautical Center, 6500 S MacArthur Blvd, Oklahoma City,
Oklahoma 79169. The Financial Operations Division telephone number is (405) 954-8845.
1 These amounts are adjusted annually for inflation. See 49 CFR § 190.223 for adjusted amounts.



Failure to pay the civil penalty will result in accrual of interest at the current annual rate in
accordance with 31 U.S.C. § 3717, 31 CFR § 901.9 and 49 CFR § 89.23. Pursuant to those same
authorities, a late penalty charge of six percent (6%) per annum will be charged if payment is not
made within 110 days of service. Furthermore, failure to pay the civil penalty may result in
referral of the matter to the Attorney General for appropriate action in a district court of the
United States.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Items 1, 2, and 4 in the Notice for
violations of 49 CFR §§ 195.452(g), 195.452(i)(1), and 195.573(e), respectively. Under 49
U.S.C. § 60118(a), each person who engages in the transportation of hazardous liquids or who
owns or operates a pipeline facility is required to comply with the applicable safety standards
established under chapter 601. As discussed above, Item 1 has been withdrawn. Therefore, the
compliance terms proposed in the Notice for that Item are not included in this Order. The
Director has indicated that Respondent has taken the following actions to address some of the
cited violations:
With regard to the violation of § 195.452(i)(1) (Item 2), the Director has indicated
that ONEOK has satisfied the proposed compliance terms.
Accordingly, I find that compliance has been achieved with respect this violation. Therefore, the
compliance terms proposed in the Notice for Item 2 are not included in this Order.
As for the remaining compliance terms, pursuant to the authority of 49 U.S.C. § 60118(b) and 49
CFR § 190.217, Respondent is ordered to take the following actions to ensure compliance with
the pipeline safety regulations applicable to its operations:
1. With respect to the violation of § 195.573(e) (Item 4), Respondent must
provide documentation that supports the adequacy and sufficiency of the new
cathodic protection criteria of -100 mV applied for the North Fence test point and
Receiver Trap test points at Warren Plant. These records must be provided to the
Director within 30 days of receipt of the Final Order.
The Director may grant an extension of time to comply with any of the required items upon a
written request timely submitted by the Respondent and demonstrating good cause for an
extension.
PHMSA requests that Respondent maintain documentation of the safety improvement costs
associated with fulfilling this Compliance Order and submit the total to the Director. 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.



Failure to comply with this Order may result in administrative assessment of civil penalties
exceeding $200,000, as adjusted for inflation (see 49 CFR § 190.223 for adjusted amounts), for
each violation for each day the violation continues or in referral to the Attorney General for
appropriate relief in a district court of the United States.
WARNING ITEM
With respect to Item 3, the Notice alleged a probable violation of Part 195, but identified it as a
warning item pursuant to § 190.205. The warning was for:
49 CFR § 195.589(c) (Item 3) ─ Respondent’s alleged failure to maintain a
record of each analysis, check, demonstration, examination, inspection,
investigation, review, survey, and test required by Subpart H in sufficient detail to
demonstrate the adequacy of corrosion control measures or that corrosion
requiring control measures does not exist.
If OPS finds a violation of this provision in a subsequent inspection, Respondent may be subject
to future enforcement action.
Under 49 CFR § 190.243, Respondent may submit a Petition for Reconsideration of this Final
Order to the Associate Administrator, Office of Pipeline Safety, PHMSA, 1200 New Jersey
Avenue, SE, East Building, 2nd Floor, Washington, DC 20590, with a copy sent to the Office of
Chief Counsel, PHMSA, at the same address. The written petition must be received no later than
20 days after receipt of the Final Order by Respondent. Any petition submitted must contain a
statement of the issue(s) and meet all other requirements of 49 CFR § 190.243. The filing of a
petition automatically stays the payment of any civil penalty assessed. The other terms of the
order, including corrective action, remain in effect unless the Associate Administrator, upon
request, grants a stay. The terms and conditions of this Final Order are effective upon service in
accordance with 49 CFR § 190.5.
___________________________________ __________________________
Linda Daugherty Date Issued
Acting Associate Administrator
for Pipeline Safety

42024025NOPV_PHC Hearing Scheduled_10172024_(23-266077)_text.pdf

October 17, 2024
VIA ELECTRONIC MAIL TO: danny.scroggins@oneok.com and bryan.lethcoe@dot.gov
Mr. Danny Scroggins
Legal Counsel
ONEOK, Inc.
100 West Fifth Street
Tulsa, OK 74103
Mr. Bryan Lethcoe
Director, Southwest Region
Pipeline and Hazardous Materials Safety Administration
8701 South Gessner Road
Suite 630
Houston, Texas 77074
Re: Notice of Hearing, ONEOK NGL Pipeline, LLC
CPF No. 4-2024-025-NOPV
Dear Mr. Scroggins and Mr. Lethcoe:
In accordance with 49 C.F.R. § 190.211, an informal hearing will be held regarding the Notice of
Probable Violation, Proposed Civil Penalty, and Proposed Compliance Order issued by the
Pipeline and Hazardous Materials Safety Administration in the above-referenced case. The
hearing will take place on April 10, 2025, beginning at 8:30 a.m. Central Time.
The hearing will take place at the PHMSA Southwest Region office, 8701 South Gessner Road,
Suite 630, Houston, TX 77074. Upon arrival at the building, attendees will be required to
present photo identification to security personnel. A contact phone number for the day of the
hearing is (713) 272-2859.
At least 10 calendar days prior to the hearing (or by March 31, 2025), both parties must submit
and exchange any additional written materials they intend to present at the hearing and the name
and email address of each attendee. This information should be provided electronically.
Materials not submitted by this date may be excluded. If you have any questions, please do not
hesitate to contact me.



Sincerely,
Larry White
Presiding Official
cc: Mr. Jason Smith, Vice President Asset Integrity, ONEOK NGL Pipeline, LLC,
jason.a.smith@oneok.com
Mr. Timothy O’Shea, OPS Southwest Region Counsel, PHMSA,
timothy.o’shea@dot.gov
Ms. Kelsey Gagnon, OPS Southwest Region Counsel, PHMSA,
kelsey.gagnon@dot.gov
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