# ONEOK ROCKIES MIDSTREAM, LLC — Notice of Amendment

- **operation:** document
- **citation:** CPF 520075044M
- **title:** ONEOK ROCKIES MIDSTREAM, LLC — Notice of Amendment
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2007-12-11
- **effective on:** Not available
- **summary:** CLOSED notice of amendment citing 195.226(c), 195.402(a), 195.402(c)(11), 195.402(c)(7), 195.402(c)(8), 195.402(e)(3), 195.402(e)(7), 195.5(a), 195.557(b), 195.563(b).
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- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/520075044M
**body:**

Notice of Amendment involving ONEOK ROCKIES MIDSTREAM, LLC. PHMSA's enforcement data identifies the cited regulations as 195.226(c),  195.402(a),  195.402(c)(11),  195.402(c)(7),  195.402(c)(8),  195.402(e)(3),  195.402(e)(7),  195.5(a),  195.557(b),  195.563(b). The case was opened on 2007-12-11 and is reported as closed as of 2008-03-03. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

520075044M_notice of amendment_12112007.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075044M/520075044M_notice%20of%20amendment_12112007.pdf

520075044m_notice of amendment_12112007_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075044M/520075044m_notice%20of%20amendment_12112007_text.pdf

520075044M_operator response to notice_01112008.pdf: https://primis.phmsa.dot.gov/enforcement-documents/520075044M/520075044M_operator%20response%20to%20notice_01112008.pdf

520075044m_notice of amendment_12112007_text.pdf

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12300 W Dakota Ave, Suite 110
Lakewood, CO B022B
U. S. Department
of Transportation
Pipeline and
Hazardous Materials Safety
Administration
NOTICE OF AMENDMENT
CERTIFIED MAIL - RETURN RECEIPT RE UESTED
December 11, 2007
Craig Forsander
Vice President
ONEOK
100 West 5th Street
Tulsa, OK 74103
CPF 5-2007-5044M
Dear Mr. Forsander:
On June 13, 2007 and July 18, 2007, a representative of the Pipeline and Hazardous Materials
Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected
Bear Paw Energy (BPE) procedures for operations and maintenance at your Grass Lands
complex in North Dakota.
On the basis of the inspection, PHMSA has identified the apparent inadequacies found within
BPE's procedures, as described below:
$195. 5 Conversion to service subject to this part.
(a) A steel pipeline previously used in service not subject to this part qualifies for
use under this part if the operator prepares and follows a written procedure to
accomplish the following:
(1) The design, construction, operation, and maintenance history of the pipeline
must be reviewed and, where sufficient historical records are not available,
appropriate tests must be performed to determine if the pipeline is in satisfactory
condition for safe operation. If one or more of the variables necessary to verify the
design pressure under $195. 106 or to perform the testing under paragraph (a) (4)
of this section is unknown, the design pressure may be verified and the maximum
operating pressure determine by-



(i) Testing the pipeline in accordance with ASME B31. 8, Appendix N, to produce a
stress equal to the yield strength; and
(ii) Applying, to not more than 80 percent of the first pressure that produces a
yielding, the design factor F in $195. 106(a) and the appropriate factors in
$195. 106(e).
(2) The pipeline right-of-way, all aboveground segments of the pipeline, and
appropriately selected underground segments must be visually inspected for
physical defects and operating conditions which reasonably could be expected to
impair the strength or tightness of the pipeline.
(3) All known unsafe defects and conditions must be corrected in accordance with
this part.
(4) The pipeline must be tested in accordance with the subpart E of this part to
substantiate the maximum operating pressure permitted by $195. 406.
(b) A pipeline that qualifies for use under this section need not comply with the
corrosion control requirements of subpart H of this part until 12 months after it is
placed into service, notwithstanding any previous deadlines for compliance.
(c) Each operator must keep for the life of the pipeline a record of the
investigations, tests, repairs, replacements, and alterations made under the
requirements of paragraph (a) of this section.
BPE has a form to be documented during a conversion of service activity however the
form does not give adequate instructions to operator personnel on how to satisfactorily
complete the conversion. An operator is required to have procedures that will provide
detailed instructions to employees during conversion to service activities.
$195. 402 Procedural manual for operations, maintenance, and emergencies.
(c) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following to provide safety during
maintenance and normal operations:
(3) Operating, maintaining, and repairing the pipeline system in accordance with
each of the requirements of this subpart and subpart H of this part.
And
$195. 422 Pipeline Repairs.
(a) Each operator shall, in repairing its pipeline systems, ensure that the repairs
are made in a safe manner and are made so as to prevent damage to persons or
property.
The following procedure was inadequate to address welding of pipeline repairs:
$195. 226 Welding: Arc burns.
(c) A ground may not be welded to the pipe or fitting that is being welded.
The adopted ONEOK welding procedure TG 1602. 201 A endix Weldin Pi elines
states that welding of the ground wire to the pipe should not be allowed. Federal pipeline
regulations mandate that welding of a ground wire to the pipe must not be allowed.



$195. 402 Procedural manual for operations, maintenance, and emergencies.
(a) General. Each operator shall prepare and follow for each pipeline system a
manual of written procedures for conducting normal operations and maintenance
activities and handling abnormal operations and emergencies. This manual shall
be reviewed at intervals not exceeding 15 months, but at least once each calendar
year, and appropriate changes made as necessary to insure that the manual is
effective. This manual shall be prepared before initial operations of a pipeline
commence, and appropriate parts shall be kept at locations where operations and
maintenance activities are conducted.
BPE's manual Section 3. 1 General Provisions page 3-2 only requires a review of normal
operation procedures annually. Federal regulation requires that procedures for normal
operation as well as those for maintenance and emergencies be reviewed once each
calendar year not to exceed 15 months.
$195. 402 Procedural manual for operations, maintenance, and emergencies.
(c) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following to provide safety during
maintenance and normal operations:
(7) Starting up and shutting down any part of the pipeline in a manner designed to
assure operation within the limits prescribed by paragraph $195. 406, consider the
hazardous liquid or carbon dioxide in transportation, variations in altitude along
the pipeline, and pressure monitoring and control devices.
The current BPE manual for normal operations does not contain a procedure for starting
up and shutting down their Riverview pipeline. There is no shutdown procedure in the
operations manual.
$195. 402 Procedural manual for operations, maintenance, and emergencies.
(c) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following to provide safety during
maintenance and normal operations:
(8) In the case of pipeline that is not equipped to fail safe, monitoring from an
attended location pipeline pressure during startup until steady state pressure and
flow conditions are reached and during shut-in to assure operation within limits
prescribed by $195. 406.
The BPE manual does not give adequate direction to require monitoring of pipeline
pressures during startup and during shut-in to ensure that pressures remain with in the
limits prescribed in $195. 406.
$195. 402 Procedural manual for operations, maintenance, and emergencies.
(c) Maintenance and normal operations. The manual required by paragraph (a) of
this section must include procedures for the following to provide safety during
maintenance and normal operations:



(11) Minimizing the likelihood of accidental ignition of vapors in areas near
facilities identified under paragraph (c)(4) of this section where the potential exists
for the presence of flammable liquids or gases.
BPE manual Section 3. 2 Desi n and 0 eratin Parameters does not provide adequate
direction for minimizing the likelihood of accidental ignition of vapors in areas that
would require an immediate response by the operator to prevent hazards to the public if
the facilities failed or malfunctioned. An operator is required to at least list common
practices to be taken that will minimize the likelihood of accidental ignition of vapors in
areas that would require an immediate response by the operator to prevent hazards to the
public if the facilities failed or malfunctioned.
$195. 402 Procedural manual for operations, maintenance, and emergencies.
(e) Emergencies. The manual required by paragraph (a) of this section must
include procedures for the following to provide safety when an emergency
condition occurs;
(3) Having personnel, equipment, instruments, tools, and material available as
needed at the scene of an emergency.
BPE's Emer enc Action Plan discusses personal protection equipment (PPE) and first
aid equipment and then states, "Additional equipment will be furnished by emergency
responders at the scene of an incident. " There is no list of possible equipment that
would most likely be required during an emergency nor are there any locations of where
anticipated emergency equipment could be obtained.
An operator's emergency procedures must have sufficient detail to provide guidance to
those responding to emergencies so they will know where anticipated emergency
response equipment resides and how to obtain it.
$195. 402 Procedural manual for operations, maintenance, and emergencies.
(e) Emergencies. The manual required by paragraph (a) of this section must
include procedures for the following to provide safety when an emergency
condition occurs;
(7) Notifying fire, police, and other appropriate public officials of hazardous liquid
or carbon dioxide pipeline emergencies and coordinating with them preplanned
and actual responses during an emergency, including additional precautions
necessary for an emergency involving a pipeline transporting a highly volatile
liquid.
BPE's Emer enc Action Plan does not describe preplanned precautions that have been
coordinated with the responding fire, police, and other appropriate public officials in the
event of a HVL emergency.
An operator is not only required to perform preplanning of precautions to be taken in the
event of an HVL emergency with public officials, they are also required to describe
those preplanned precautions in their emergency response procedures.



9. $195. 557 Which pipelines must have coating for external corrosion control?
(b) Converted under Sec. 195. 5 and-
(1) Has an external coating that substantially meets Sec. 195. 559 before the pipeline
is placed in service; or
(2) Is a segment that is relocated, replaced, or substantially altered.
BPE manual Section 3. 3 Corrosion Prevention does not adequately address coating
requirements for pipelines that are being converted to hazardous liquid service, or are
being relocated, replaced, or substantially altered.
An operator must have guidance that requires adequate coating if a pipeline is relocated,
replaced or substantially altered or if a pipeline had coating meeting $195. 559 before it
was converted to service.
10. $195. 563 Which pipelines must have cathodic protection?
b) Each buried or submerged pipeline converted under Sec. 195. 5 must have
cathodic protection if the pipeline—
(1) Has cathodic protection that substantially meets Sec. 195. 571 before the
pipeline is placed in service; or
(2) Is a segment that is relocated, replaced, or substantially altered.
BPE manual Section 3. 3 Corrosion Prevention does not adequately address cathodic
protection requirements for pipelines that are being converted to hazardous liquid service,
or are being relocated, replaced, or substantially altered.
An operator must have guidance that requires adequate cathodic protection if a pipeline is
relocated, replaced or substantially altered or if a pipeline had cathodic protection
meeting $195. 571 before it was converted to service.
11. $195. 567 Which pipelines must have test leads and what must I do to install and
maintain the leads?
(c) Maintenance. You must maintain the test lead wires in a condition that enables
you to obtain electrical measurements to determine whether cathodic protection
complies with Sec. 195. 571.
BPE manual Corrosion Prevention does not provide detailed instruction to operator
personnel on how to maintain test leads. The current BPE manual references $195. 567(c)
for those instructions. Referencing $195. 567 "alone" is not sufficient guidance to
operator personnel for ensuring test leads are maintained so that electrical measurements
can be taken.



Res onse to this Notice
This Notice is provided pursuant to 49 U. S. C. g 60108(a) and 49 C. F. R. g 190. 237. Enclosed as
part of this Notice is a document entitled Response Options for Pipeline Operators in
Compliance Proceedings. Please refer to this document and note the response options. 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). If you do not respond within 30 days
of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in 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 Final Order.
If, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in
this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies
(49 C. F. R. $ 190. 237). If you are not contesting this Notice, we propose that you submit your
amended procedures to my office within 30 days of receipt of this Notice. This period may be
extended by written request for good cause. Once the inadequacies identified herein have been
addressed in your amended procedures, this enforcement action will be closed.
In correspondence concerning this matter, please refer to CPF 5-2007-5044M and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely
/
is Hoidal
Director, Western Region
Pipeline and Hazardous Materials Safety Administration
cc: PHP-60 Compliance Registry
PHP-500 G Davis (¹119570)
Enclosure: Response Options for Pipeline Operators in Compliance Proceedings
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