BEFORE THE CORPORATION COMMISSION OF OKLAHOMA

APPLICANT:

PATRICIA L. FRANZ,
DIRECTOR, TRANSPORTATION
DIVISION, OKLAHOMA
CORPORATION COMMISSION

RESPONDENT:

OKLAHOMA NATURAL GAS

COMPANY, a division of ONE GAS,
INC.

RELIEF SOUGHT:

CONTEMPT AND FINES

CAUSE NO.
EN

201600156

El. II

COMPLAINT
I.

SEP23 2016

PARTIES:

COURT CLERK'S OFFICE - 0KG

CORPORATION COMMISSION
OF OKLAHOMA

Applicant:

Patricia L. Franz
Director, Transportation Division
Oklahoma Corporation Commission

Respondent:

Oklahoma Natural Gas Company, a division of ONE Gas, Inc.

do National Registered Agents, Inc. of Oklahoma
1833 S. Morgan Rd.
Oklahoma City, OK 73128

II. ALLEGATION OF FACTS:

A. This enforcement action results from an investigation conducted by the Transportation
Division's Pipeline Safety Department following a pipeline explosion on January 2, 2016
at 12505 Whispering Hollow Drive in Oklahoma City, Oklahoma. The Pipeline Safety
Department produced a summary report ("Report") of its findings following the
investigation, which is attached as Exhibit A. The Pipeline Safety Department also issued
a Notice of Probable Violation letter ("NOPV") that is attached as Exhibit B. As detailed
in the Report and NOPV, the Pipeline Safety Department documented eight previous
pipeline leak failures from December 1983 to February 2012 in the same area as the
explosion. Report Ex. A, at 7. Along with the leak detection methods used the day before
the explosion, the Applicant alleges that, pursuant to the Report and NOPV, proper
procedures were not used to monitor and investigate pipeline leaks along a natural gas
main line in the area of Whispering Hollow Drive in Oklahoma City.
Therefore, Patricia L. Franz, Director of the Transportation Division of the Oklahoz
Corporation Commission ("Commission"), hereby complains and alleges that OklahoM
Natural Gas Company, a Division of ONE Gas, Inc. ("Respondent"), has not comp1i4'
with Commission rules and the Code of Federal Regulations ("C.F.R.") concerning th
T.

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operation of natural gas pipeline transportation systems (the particulars of which are
more fully set out below) in violation of Oklahoma Administrative Code ("OAC")
Chapter 165:20-5 et seq., and 49 C.F.R. 192 et seq., as adopted by OAC 165:20-5-21.
Applicant contends judgment for the Commission should be rendered and Respondent be
found in violation thereof.
B.

Specific alleged acts of violation and authority thereto include:

COUNT ONE:

Respondent failed to perform, or document performance of,

continued surveillance when responding to eight leak
failures of a natural gas pipeline as noted in the Report in
violation of 49 C.F.R. 192.613, 192.13(c). Each of the
eight failures are subject to penalties of up to ten thousand
dollars ($10,000) per day, per violation, not to exceed five
hundred thousand dollars ($500,000) per violation as
provided by Title 17 Okla. Stat. 6.1 (1999) (amended
2016).

COUNT TWO:

Respondent failed to investigate, or document investigation

of, the cause of eight leak failures of a natural gas pipeline
as noted in the Report in violation of 49 C.F.R. 192.617,
192.13(c). Each of the eight failures are subject to penalties
of up to ten thousand dollars ($10,000) per day, per
violation, not to exceed five hundred thousand dollars
($500,000) per violation as provided by Title 17 Okla. Stat.
6.1 (1999) (amended 2016).

COUNT THREE:

Respondent failed to properly perform a bar hole survey,

required by Respondent's written procedures, when
responding to a customer-reported gas leak the day before
the explosion, January 1, 2016, in violation of 49 C.F.R.
192.615, 192.13(c). The failure to perform a survey is
subject to a penalty of up to ten thousand dollars ($10,000)
per day, per violation, not to exceed five hundred thousand
dollars ($500,000) per violation as provided by Title 17
Okla. Stat. 6.1 (1999) (amended 2016).

IlL LEGAL AUTHORITY:

This matter is set for hearing under statutory authority of Title 17 Okla. Stat. 2, 6,
6.1, 9; Title 52 Okla. Stat. 5; OAC 165:5-19-1, 165:20-5-21, 165:20-13 and the Oklahoma
Constitution, Article IX 18, 19.

IV. RELIEF SOUGHT:

A FINDING OF CONTEMPT AGAINST RESPONDENT AND A PROPOSED
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FINE AND/OR SUCH OTHER PUNISHMENT AS THE COMMISSION DEEMS

NECESSARY, OR SPECIFIED BY LAW.
2.
NOTICE IS HEREBY PROVIDED THAT APPLICANT MAY SEEK
COMPLIANCE AS WELL AS THE MAXIMUM LAWFUL AMOUNT PER VIOLATION
PER DAY PROVIDED BY TITLE 17 OKLA. STAT. 6.1 (1999) (AMENDED 2016), OR
SUCH OTHER FINE OR PENALTY AS THE LAW PERMITS, WHICHEVER IS GREATER.
3.
UNLESS DISMISSED, FAILURE TO APPEAR AT THE TIME AND PLACE
DIRECTED BY THE APPEARANCE DATE, SHALL BE TAKEN AS A CONFESSION AND
THE MAXIMUM REQUESTED AMOUNT ASSESSED.
4.
ANY FINES, FEES OR COSTS ASSESSED SHALL BE A FIRST LIEN ON
ALL PROPERTY OF RESPONDENT. FAILURE TO PAY ANY FINES, FEES OR COSTS
ASSESSED OR OUTSTANDING SHALL RESULT IN A WRIT OF EXECUTION TO SEIZE
AND SELL SUFFICIENT PROPERTY OWNED BY RESPONDENT TO SATISFY THE
FINE OWED, PURSUANT TO TITLE 17 OKLA. STAT. 6.
Dated this

13

day of September, 2016.

Respectfully submitted,

Mark A. Willingham, OBA #22769

Senior Attorney - Transportation Division
Oklahoma Corporation Commission
P.O. Box 52000
Oklahoma City, Oklahoma 73152-2000
(405) 522-1638; Fax (405) 521-4150
M.Willingham@occemail.com
Attorney for Applicant
Zach D. Duvall, OBA #31543
Assistant General Counsel
Oklahoma Corporation Commission
P.O. Box 52000
Oklahoma City, Oklahoma 73152-2000
(405) 521-4749; Fax (405) 521-4150
Z.Duvall@occemail.com
Attorney for Applicant

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VERIFICATION

STATE OF OKLAHOMA

ss:

COUNTY OF OKLAHOMA

As Assistant General Counsel for the Transportation Division, Oklahoma Corporation

Commission, I hereby certify that the information contained in the above and foregoing
Complaint is true and correct to the best of my knowledge and belief.

Mark A. Willingham, OBA #22769

Attorney for Applicant
Oklahoma Corporation Commission

Subscribed and sworn to before me this 2 5 day of September, 2016.

Notary Public
tiHISI

My Commission expires:

B.
# 00012489
07)2a/20 I

,,

Op

-4-

h Am~
-

Exhibit A
Pipeline Safety Department Report

BOB ANTHONY

TODD HIETT

Commissioner

DANA MURPHY

Commissioner

Commissioner

OKLAHOMA
CORPORATION COMMISSION

Transportation Division
Pipeline Safety Department
www.occeweb.com

P.O. BOX 52000

OKLAHOMA CITY, OKLAHOMA 73152-2000

2101 North Lincoln Blvd, Room 231

Oklahoma City, OK 73105

LA
E
IQ-'e

Office
FAX:

Report of the Pipeline Safety Department

Home Explosion January 2, 2016
12505 Whispering Hollow Drive
Oklahoma City, Oklahoma

Submitted - August 10, 2016

SERVICE - ASSISTANCE - COMPLIANCE

EXCELLENCE IS OUR STANDARD

(405) 521-2258
(405) 521-3455

I.

The Incident

Incident No:
Type of System:
Incident Type:
Location:
Date:
Time:
Owner/Operator:
Property Damage:
Fatalities:
Injuries:
Material Released:
Pipeline Pressure:
Test Pressure:
Component Affected:

PLS-NG- 16-222
Natural gas distribution
Leak, explosion and fire
Oklahoma City, Oklahoma
January 2, 2016
3:19 a.m. central standard time
Oklahoma Natural Gas Company
$509,422 estimated
None
I requiring in-patient hospitalization
Natural gas
49 pounds per square inch, gauge
100 pounds per square inch, gauge (8/11/1983)
108 pounds per square inch, gauge (2/19/2016)
4-inch polyethylene natural gas distribution pipeline

On January 2, 2016, at 3:30 a.m., a natural gas explosion destroyed the residence located at 12505
Whispering Hollow Drive in Oklahoma City, Oklahoma, injuring a man at the residence. An estimated
50 residences in the surrounding area sustained damage, with five residences damaged so extensively that
demolition was required. Property damage was estimated to be in excess of $500,000 dollars.

II.

Incident Investigation

Oklahoma Natural Gas Narrative

Events Leading Up to the Explosion
On January 1, 2016, at 3:50 p.m., the homeowner at 12501 Whispering Hollow Drive, Oklahoma
City, Oklahoma, called Oklahoma Natural Gas Company ("ONG") to report a gas odor complaint. An
ONG dispatcher ("Dispatcher 1") dispatched an ONG customer service technician ("Technician 1"), who
arrived on location at 4:52 p.m. and began his investigation.
After determining there was no gas leak at 12501 Whispering Hollow Drive, the technician
moved to 12505 Whispering Hollow Drive. During his investigation, he discovered the presence of gas
in the backyard of 12505 Whispering Hollow Drive. The technician classified the leak as a nonhazardous gas leak and informed the homeowner a work crew would be back on Monday, January 4,
2016, to repair the leak. Technician I left the location at 6:13 p.m.
On January 1, 2016, at 11:50 p.m., the homeowner at 12509 Whispering Hollow Drive,
Oklahoma City, Oklahoma, called ONG to report a gas odor complaint. A different ONG dispatcher
("Dispatcher 2") dispatched another ONG customer service technician, ("Technician 2") who arrived on
location at 12:27 a.m. and began his investigation.

Page 2

Technician 2 parked his vehicle in front of 12508 Whispering Hollow Drive. Upon leaving his
vehicle, he smelled gas coming from the direction of 12508 Whispering Hollow Drive. He began his
investigation at 12508 Whispering Hollow Drive where he identified a thread leak at the customer's
regulator and turned off the gas to the residence.
Technician 2 proceeded to 12504 Whispering Hollow Drive where he knocked on the front door
to get permission to enter the backyard, but did not get a response. He returned to 12508 Whispering
Hollow Drive where he rebuilt the setting and turned the gas back on.
Technician 2 then went to 12505 Whispering Hollow Drive and knocked on the door of the
residence. There was no response to his knocks.
On January 2, 2016, at 12:55 a.m., an Oklahoma City police officer responded to a suspicious
subject ringing the doorbell and knocking on the door at 12504 Whispering Hollow Drive. Upon
arriving, the officer was flagged down by Technician 2 who explained to the officer that he was in the
area responding to an odor complaint and was knocking on the door to gain access to the backyard. The
officer advised the calling party the suspicious subject was an ONG worker and left the area.
Technician 2 gained access to the backyard of 12504 Whispering Hollow Drive and found a small
leak under the regulator. He repaired the leak and proceeded to 12509 Whispering Hollow Drive to
continue his investigation. The technician did not identify any gas at the residence itself, but did identify
gas near the main in the backyard. The technician told the homeowner he was going to turn off the gas to
the residence.
At 1:54 a.m., the technician called the dispatcher and requested assistance in locating the gas
leak. The on-call crew arrived on location at 2:59 a.m. The technician briefed the on-call crew of his
findings and the crew proceeded to the backyard of 12509 Whispering Hollow Drive.
Home Explosion
On January 2, 2016, at 3:19 a.m., while ONG's on-call crew was in the backyard of 12509
Whispering Hollow Drive, the residence at 12505 Whispering Hollow Drive exploded. ONG's on-call
crew attempted to call 911, but all lines were busy. The onsite crew called ONG dispatch and requested
they call 911.
Emergency Response
ONG's on-call crew assisted the injured resident of 12505 Whispering Hollow Drive, providing
clothing, water, and shelter in an ONG vehicle. The on-call crew assisted a couple at 12501 Whispering
Hollow Drive to exit their residence. The on-call crew directed the paramedics to the injured parties. The
injured parties were transported to area hospitals by ambulance. The injured party from 12505
Whispering Hollow Drive was hospitalized with burns to his arms and chests. The husband and wife
residing at 12501 Whispering Hollow Drive were treated for breathing problems and released.
On January 2, 2016, at 3:36 a.m., fire and police arrived on location and began controlling the
scene.

Page 3

Control of the Incident

On January 2, 2016, at 5:54 a.m., ONG personnel used "squeeze off' tools to pinch the 4-inch
polyethylene ("PE") main to isolate and cut off the flow of gas to the area of the main between 12409 and
12517 Whispering Hollow Drive.
ONG Incident Investigation & Service Restoration
ONG hired Baker Engineering and Risk Consultants, Inc. ("Baker Risk") to conduct a postincident investigation.
On January 2, 2016, at 4:50 p.m., the on-scene investigator for Baker Risk gave ONG permission
to cut and cap both ends of the isolated segment of the 4-inch PE main. At 5:26 p.m.. ONG completed
the cutting and capping of the 4-inch main.
On January 3, 2016, at 8:32 a.m., the isolated line section between 12409 and 12517 Whispering
Hollow Drive was placed on an air test. The main was leak tested to 49 pounds per square inch, gauge
("psig"). Within two-minutes, the pressure dropped to 5 psig. ONG then began the process of excavating
the 4-inch PE main to locate the leak.
Approximately twenty-two (22) feet south of the gas meter location at 12505 Whispering Hollow
Drive, a fusion joint was found to be cracked. A three-foot section of the 4-inch PE main, including the
failed fusion joint, was removed and sent to a secured offsite area. A new segment of 4-inch PE pipe was
installed using electro-fusion couplings. The isolated section of the 4-inch PE main (12409 to 12517
Whispering Hollow Drive) was successfully leak tested to 49 psig. Gas service to the residences in the
isolated section, with the exception of the residences at 12413, 12501, 12505, 12509, and 12515
Whispering Hollow Drive, was restored.
Examination of the Failed 4-inch Fusion Joint
On February 10th and I 1th, 2016, the three-foot segment of 4-inch PE gas main with the failed
fusion joint was examined at the Element Materials Technology facilities in Broken Arrow, Oklahoma.
The report prepared by Element Materials Technology, dated February 26, 2016, only reports what was
observed during the evaluation. No conclusion(s) of what caused the fusion joint to fail was reported.

0CC Pipeline Safety Dept. Interviews of 0NG Personnel, February 3, 2016

Technician 1
Technician 1 received a leak complaint call from dispatch on his cell phone. (See time lines given
in section titled "Oklahoma Natural Gas Narrative - Events Leading up to the Explosion" above.)
Technician 1 then reviewed the leak complaint order on his laptop. Upon arriving at 12501 Whispering
Hollow Drive and exiting his vehicle, he did not smell any gas.

Page 4

Technician 1 began his investigation by conducting a bar hole survey' around the residence. He
found no indication of gas around the residence. He then proceeded to 12505 Whispering Hollow Drive
and found a small gas leak at the regulator. Technician 1 repaired that leak and conducted a gas leak
check of the gas meter. He performed a six-minute shut in test on the customer's yard line. No leakage
was found. He also conducted a bar hole survey around the meter and downstream to and around the
residence. Technician 1 found gas in concentrations ranging from 100 percent to 33 percent, west of the
meter. He also identified 30 percent gas at the meter itself.
ONG provided a diagram of the bar hole survey performed by Technician 1. The diagram
reflects Technician 1 conducted a bar hole survey at the corners of the residence, along the customer's
fuel line between the residence and the gas meter, at the gas meter, and west of the gas meter. Technician
1 explained that he did not perform a bar hole survey to the north or south of the gas meter location
because he believed the main was located on the west side of the fence, away from the residence.
Technician I then called his team leader and discussed his findings. The leak was classified as
non-hazardous. He informed the homeowners at 12501 and 12505 Whispering Hollow Drive that ONG
would be back on Monday, January 4, 2016, to repair the leak.
Technician 2
On January 2, 2016, at 12:01 a.m., Technician 2 was dispatched to 12509 Whispering Hollow
Drive to check an odor complaint by residents. Technician 2 arrived to the location at 12:27 a.m., and
parked his truck in front of the residence located at 12508 Whispering Hollow Drive. Upon exiting the
vehicle, he smelled the odor of gas coming from the direction of 12508 Whispering Hollow Drive.
Technician 2 went to 12508 Whispering Hollow Drive and gained access to backyard. Technician 2
identified and repaired a small gas leak at regulator on the meter set.
He then went to 12504 Whispering Hollow Drive and knocked on front door to gain access to the
backyard to check for a gas leak. He did not receive a response to his knocks. Technician 2 returned to
12508 Whispering Hollow Drive and painted the meter he had repaired at that address with corrosion
resistant paint. Technician 2 was finally able to gain access to the backyard of 12504 Whispering Hollow
Drive with the assistance of an Oklahoma City police officer. At that residence, Technician 2 identified
and repaired a small gas leak at the meter set.
Technician 2 then went to 12509 Whispering Hollow Drive and met with the homeowner, who
advised him of a strong gas odor in his backyard. Upon investigation, Technician 2 identified a small gas
leak on meter set and repaired the leak. Technician 2 went to 12505 Whispering Hollow Drive and
knocked on the door to gain access to the backyard. There was no response to his knocks. Technician 2
returned to 12509 Whispering Hollow Drive, where he continued to smell gas. He proceeded to perform
a bar hole survey along the main to the south and the north. Technician 2 identified gas concentrations
ranging from 20 percent to 30 percent. He then returned to 12505 Whispering Hollow Drive and knocked
on the door. There was no answer.

A bar hole survey involves creating holes at regular intervals in the area of a suspected pipeline leak and testing
inside the holes with a gas detection device.

Page 5

Technician 2 called ONG dispatch and advised them he was in need of additional assistance. He
spoke to a Pipeline Inspector for ONG, and advised the Inspector of a possible leak on the service line at
12509 Whispering Hollow Drive. Technician 2 then advised the homeowner at 12509 Whispering
Hollow Drive that an ONG crew was being dispatched to assist him in locating the gas leak. He then left
the location.
Upon returning to the location, Technician 2 found the on-call crew at the location preparing to
suit up in protective clothing. The on-call crew and Technician 2 proceeded to the backyard of 12509
Whispering Hollow Drive. At 3:19 a.m., while the on-call crew was in the backyard of 12509
Whispering Hollow Drive, the residence at 12505 Whispering Hollow Drive exploded. Technician 2
attempted to call 911, but all of the lines were busy. Technician 2 then called ONG dispatch and
requested they call 911.
Technician 2 was questioned about his knowledge of the gas leak, which had been located during
the late afternoon of January 1, 2016, in the backyard of 12505 Whispering Hollow Drive. He indicated
he was not advised of that previously identified leak.

Dispatcher 1
On the morning of Friday, January 1, 2016, Dispatcher 1 clocked in at 8:00 a.m., and clocked out
at 6:00 p.m. Dispatcher 1 was asked if she had access to past work history in the area. Dispatcher 1
stated that only work orders or emergency calls which have not been closed out are available to the
dispatchers.

Dispatcher 2
On the night of January 1, 2016, Dispatcher 2 clocked in at 10:00 p.m. and was on duty until 6:00
a.m. the morning of January 2, 2016. Dispatcher 2 was asked if she had access to work history in the area
of the explosion when she dispatched Technician 2 to that area. Dispatcher 2 stated that dispatchers do
not have access to any past work orders or emergency calls once orders or calls have been closed out.

Ill. Construction, Survey & Repair History of 4-Inch PE Main

Construction
On June 15, 1983, construction of the 4-inch PE gas main began. Construction was completed on
August 11, 1983. The 4-inch PE main consisted of 1273 feet of pipe, joined with fusion joints. There
was no record of the number of 4-inch joints used to make up the 1273 feet. On August 11, 1983, the
main was successfully pressure tested to 100 psig.

Leakage Survey Records

Date of Survey

Results

Leak Location

% Gas

Leak Class
No records available

1983 through 2001

Whispering Hollow Drive

2/13/2009

12301 Whispering Hollow Drive

Page 6

59% gas

Class 2 Leak

2/13/2009

12409 Whispering Hollow Drive

5% gas

Class 3 Leak

2/17/2012

12309 Whispering Hollow Drive

7% gas

Class 2 Leak

2/17/2012

12405 Whispering Hollow Drive

2% gas

Class 3 leak

2/18/2013

Whispering Hollow Drive

No leaks found during survey

2/19/2014

Whispering Hollow Drive

No leaks found during survey

5/4/2015

Whispering Hollow Drive

No leaks found during survey

Leak Repair History

Date

Location

Listed Cause

How Identified

12/21/1983

12509 Whispering Hollow Drive

Leak in butt fusion joint

Customer reported leak

1/24/1985

12609 Whispering Hollow Drive

Butt fusion pulled apart

Customer reported leak

12/24/1988

12405 Whispering Hollow Drive

Leak in butt fusion joint

Customer reported leak

11/19/1990

12501 'Whispering Hollow Drive

Main pulled apart

Customer reported leak

3/12/1992

12609 Whispering Hollow Drive

Butt fusion butt weld pulled apart

Customer reported leak

11/13/2000

12517 Whispering Hollow Drive

Butt fusion failure

Customer reported leak

2/13/2009

12301 Whispering Hollow Drive

Service tee leak

Company leakage survey

12/29/2010

12409 Whispering Hollow Drive

Butt fusion failure

Company leakage survey

2/14/2012

12309 Whispering Hollow Drive

Butt fusion failure

Company leakage survey

1/2/2016

12505 Whispering Hollow Drive

Butt fusion failure

Customer reported leak

With the exception of the laboratory analysis performed as the result of the January 2, 2016
incident, the only documentation available for any of the previous failures was what was shown on the
leak repair reports. The reports detailed only the location and type of failure for each leak, but not the
root cause of the failures.

IV. Procedural Requirements

ONG has separate written procedures for customer service personnel and operational personnel.
Customer service personnel respond to leak complaints. If a leak is discovered which is beyond their
ability to handle, the customer service personnel are to report the leak to the dispatcher and a work order
is generated to repair the leak.
ONG's written procedures address how soon a leak must be repaired, depending upon the
classification of the leak. In addition, there are written procedures concerning failure investigations and
continuing surveillance of pipelines and facilities.
Relevant portions of applicable procedures are set out in this section: 2

Applicable procedures are not limited to those set forth in this report.

Page 7

Service Order Procedure 301

SERVICE ORDERS
Subject:

Leak, Odor, and fume Investigation

Issued:

01/95

Revised:

11/08

SCOPE

Use this procedure to investigate leak, odor, and fume reports.

NOTE:

If the leak investigation and response process is beyond your scope of abilities,
immediately callyour supervisor to report the situation. Be prepared to stand by and

follow any additional instructions.

Technicians shall make inspections at customer premises upon the request of a
customer or city officials and when for any reason a company employee suspects that
leakage exists. Immediate steps shall be taken to locate and/or eliminate leakage.
REFERENCES

GOSM 501-3 Classi1iing Leaks

DEFINITIONS

Upstream of Meter

The gas piping before the meter.

Downstream of Meter The gas piping from the outlet side of the meter to the customer appliance.
A hazard is a situation that involves leakage of gas to the extent that danger of fire or
explosion is immediate or that involves leakage of fumes to the extent that danger to
life is immediate.

Hazard

PROCEDURE

Leak Investigation

1. Take Combustible Gas Indicator (CGI) readings as you approach the

structure and at the door.

3. If a hazard is not immediately apparent:

Hazard NOT
Immediately Apparent

Single Installation
1. Knock on the door - do not use the doorbell.
2.

Investigate Gas

Notify the customer you are investigating a report of a leak, odor or fume.

Investigate a gas leak outside on a buried pipeline as follows:

Leaking Outside
Bar

Hole

Survey

1. Determine whether it is safe to leave the gas on.

a. Perform a bar hole survey to pinpoint any possible leaks. Use a CGI to check

Page 8

all directions around the leak area to determine if there ism igrati on. Check
around all structures, over the buried pipelines in the area, sewer, manhole
covers and at any other source where gas may migrate through or to.
It is important to determine and document the full extent of a leak migration
pattern. Check the area of leakage in a minimum of four directions until zero
(0% gas) readings are obtained.
Document the area of leak migration on the Pipeline Leak and Repair (PL&R)
form (upstream of meter) and/or Service Order (downstream of meter).
b. Classify a leak outside in accordance with GOSM 501-3 Classifying Leaks.

Classify Leak:
Outside

- Class 1 - Class2 - Class3 Hazardous Leak

Outside

2.

Hazardous, discontinue service

Not hazardous,gas maybe lefton
Not hazardous,gas maybe lefton

If the leak outside is hazardous (Class 1) or you are not able to locate and
classify the leak:
a. Discontinue service.
b. Either seal or lock or physically disconnect meter assembly and seal open
pipe ends.
c. Notify the customer of the situation and discuss arrangements to replace or
repair the line.
d. Notify the appropriate personnel for line repair or replacement.

Non-Hazardous Leak
Outside

3. If the leak outside is not hazardous (Class 2 or 3):

a. The gas may be left on.

b. Notify the customer of the situation, that costs may be incurred as a result of
leaving the service on. and discuss arrangements to replace or repair the line.
NOTE: Service should be discontinued if the odor is objectionable to the customer.
c. Notify the appropriate personnel for line repair or replacement.
d. Light pilots and check the appliance(s) for proper operation.
Document Leak

4. Document the leak investigation, results according to the following:

Upstream of Meter
a.

Upstream of the Meter:

- Complete the Leak Report portion of Form 268. Pipeline Leak and
Repair (PL&R)Report
- Complete the Service Order: Document investigation work and results on
the completion screen

Downstream of Meter
b. Downstream of the Meter
- Complete the Service Order:

Page 9

 On the completion screen include bar hole survey results and indicate
the customers approval to maintain service at the customers cost
Notify appropriate personnel for line repair or replacement
Request a Service Order to re-check the leak within 7 business days.
-- Complete a Yard Line Agreement (Form 1930). in accordance with
local yard line replacement process

ONG GOSM 501-3

Subject:

General Classif5ing Leaks

Issued:

03-01-95

Revised: 04-07-2014
ONG GOSM 501-3 has been superseded by the ONE Gas standard OKEdis2.1802 Leak, Classification.
Investigation and Repair Schedule.

OKEdis2.1802
Subject: LEAK INVESTIGATION, CLASSIFICATION AND REPAIR SCHEDULE
Procedure No.: OKEdis2.1802
Owner: /ice President Engineering

Original Issue: 8/29/13

Date Revised: 2/15/2015

Date Effective: 3/1/2015

PURPOSE/EXPECTATION:
Usethis Procedure to investigate with due expediency reports of leaks and to classify leaks located on Company-owned or
Company-maintained natural gas facilities. The Procedure provides the required action and repairschedules foreach
leak classification. The Procedure also provides guidance to notify a customer of a leak found on a customer-operated
pipeline. This Procedure applies to Kansas Gas Service, Oklahoma Natural Gas andlexas Gas Service unless otherwise
stated.
The duties and processes described wthinthis Procedure shall be performed in accordance with the ONE Gas
Environmental Safety and Health (ESH) Procedures.

2. DEFINITIONS:
2.1. Adjacent Buildings
An inhabitable structure that is next to the area of leakage or damage, but no more than 150 feet away from the area.
This includes a 360-degree pattern and structures that may be across a street, aly, easement, etc. See examples in
Figure 1, Figure 2. and Figure 3.
2.2. Leak
A leak is a hole oropening that allows an unintentional escape of gas from the pipeline. A IBak includes all underground
leaks, all hazardous aboveground leaks, and all non-hazardous aboveground leaks that cannot be eliminated by
lubrication, austment, orthtening.

Page
10

2.3 Leak Count

All leak(s) within a five (5)-foot span of pipeline shall be counted as a single leak only when the leak meets the
following criteria:
Same excavation;
Same asset (e.g. service, main, riser, valve, coupling, etc.); and
Same leak cause.
Otherwise, the leaks shall be counted as multiple leaks and documented on separated leak reports.
2.3. Hazardous Leak
Ahazardous leak isaGrade 1 leak asdefined in Section 7.1.1.
2.4. Repair
Repairmeans a Company-approved permanent ortemporary repair that stops the flow of gas out of the pipe.
2.5. Temporary Repair
Atemporary repair isa repairthat stops theflow of gas out ofthe pipe but cannot be leftforan extended period of time
(see Table 2).
2.6. Leak Cleared
Clearing a leak means to verFy a gas concentration of 0% at the repair site. The leak can be cleared at either the time
ofrepairoratthetime of a repairverify.
2.7. RepairVerify
Repair verify means checking for the presence of gas after a repair has been made to a leak because the leak was not
cleared atthe time of repair.
2.8. Customer-Operated Pipeline
A customer-operated pipeline is a pipeirie, service line, master meter system. ancillary me, or fuel line owned by the
customer for which the customer is responsible for operation and maintenance.
3. LEAK DETECTION INSTRUMENTS:
3.1. A combustible gas indicator (CGF), remote-methane leak detector (RMLD), flame ionization (Fo unit. or other
Company-approved instrument may be used to investigate an outside leak.
3.2. A CGI or other Company-approved leak detection instrument providing a percentage of gas in airshall be used to
classify an outside bak.
4. GENERAL:
4.1. Thefirst and foremost concern shall bethe safety of the public and employees. Incoordination and cooperationwfth
any governmental emergency response personnel on the scene, the first responder has the authority to take all steps
that are necessary to protect the public and minnuzethe impact to the integrity of the pipeline system. The first
responder shall secure the area to protect human We and take appropriate steps to make the leak safe, notify a
supervisor or dispatcher of the response status, and remain atthe leak bcatcn until proper personnel arrive to
relieve/assist the first responder.
4.1.1. All employees responding to a potential emergency situation shallfirst take action to accomplish, at a
minimum,the following steps in the order shown: Protection of the publicfrom possible niry;
4.1.2. Protection of Company personnel and others conducting the investigation from possible rijury;
4.1.3. Protection ofpropertyfrom possible damage ,- and
4.1.4. Elimination or making safe the source of gas leakage or other condition that led to the emergency situation.
6.

LEAK INVESTIGATION
6.2

Determine the Location of Leakage and Migration Patterns

6.2.1. Look for spots of brown grass, dead or dying shrubs or trees, bubbling water,
discoloration of the soil (vegetation surveys), and soil subsidence.
6.2.2 Look for recent excavations and evidence of construction activity.

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6.2.3. Use a CGI. FL, or other Company-approved leak detection instrument to

determine if a leak is present.
6.2.4. If a leak is indicated, determine the location of the source of the leak by
performing a bar hole test along the pipeline to find the greatest concentration of
gas. Determine the full extent of leak migration as follows:
6.2.4.1 Check the area of leakage in a minimum of four (4) directions until 0%
gas reading are obtained. Particular attention should be given to the
location of valves, tees, fittings, and connections;
6.2.4.2 Place a number of bar holes preferably two (2) to five (5) feet apart, not
to exceed 15 feet apart, beginning at the point where leak is located.
6.2.4.3 If the leak is near a structure orsuspectedtobemratrgtoastructure, place
number of bar holes at closer intervals along the structure and along the yard line and/or
service line;
6.2.4.4 If investigating a new leakwhere the main material is known to be bare steel, cast
iron, wrought iron, ductile eon, ABS, or PVC, check the area for at bast 500 feet over
the main or longer as needed in each direction from the occurrence;
6.2.4.5 Check for gas in vaults, sanitary sewers, and/or ducts. If found, see Section 6.4; and
6.2.4.6 Use gas purging equipment, if needed, to help pinpoint the location of the leak
(see OKEdis2 .1814 Purging Gas from Soil).
6.2.5

Additional perimeter checks shalt be made in residential areas where houses are whin 100 feet of
each other. The extent of the investigation of leakage in areas of wall to wall pavement shall be
determined on an individual basis. The perimeter checks shall be done according to the following
at a minimum:
6.2.5.1 Perform checks over the approximate location of the service line entrance into the
building and over the service line from the buildir tothe main. Ifthereisan indication of
gas when using any approved instrument other than a CGI unit, further investigation
shall be made usng a CGI and bar holes. If bar hole is used, a test shall be made at
the nlet and outlet risers and should be nocloserthan 8" tothe riser;
6.2.5.2 Perform a perimeter check completely around the structure where the gas leakage was
reported, using gas detection equipment; and
6.2.5.3 When accessible, additional checks shall be made over the service lines of the
adjoining structures and at the foundation walls of the adjoining structures
nearest to the structure where leakage was discovered and/or reported and
directly across the street, alley or easement from where the gas leakage was
discovered and/or reported.

6.2.6
6.2.7

If the investigation of a reported bak provides a 0% sustained reading, no classifiable leak is

present.
If a sustained reading on a leaks obtained, classify the leak on Company-owned facilities and take
the required action(s) for leak repair according to Section 7.

ONG GOSM 505-10

PURPOSE

To provide procedures for the continuing surveillance of pipelines and facilities.

REFERENCES

CFR49: Part 192.613, 192.619.

SUMMARY

Following is a procedure for the continuing surveillance of pipelines and facilities.

This procedure lists the patrols, inspections and surveys that are performed on

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12

Oklahoma Natural pipelines and facilities. These methods of surveillance assist in

monitoring pipelines and facility conditions and prioritizing and budgeting repairs
and rebuilds.

General Statement

Oklahoma Natural personnel routinely monitor all aspects of pipeline operations and
pipeline conditions. Line patrols, leakage surveys and cathodic protection surveys
are just a few of the numerous methods used to oversee the integrity of the pipeline
system. In addition to monitoring purposes, information gained from these surveys
assists personnel in the scheduling and budgeting of repairs, rebuilds, and
maintenance.

Responsibility
Superintendent

Action
Monitor the results of the listed surveys and inspections (see table on page 3) and
other surveys. Ensure that the overall integrity of the pipeline system is being
maintained and that repairs, rebuilds, and maintenance are being performed as
required.
Perform additional monitoring of the pipeline system such as:
In flood plains, creek crossings, and other vulnerable areas.
Surveillance for evidence of unannounced third-party excavation near pipelines.
Surveillance for evidence of unplugged meter risers.
Continuous surveillance for abnormal operating conditions.
Based on the results of these surveys and inspections, schedule repair or
replacement of pipelines and facilities. Remedial action related to exposed plastic
pipe shall be completed as soon as practical, not to exceed 12 months from
discovery. If the segment can not be repaired or replaced, reduce the maximum
allowable operating pressure in accordance with 192.619(a) and 192.619(b).
Prioritize pipeline repair or replacement based on the physical condition of the pipe,
location of the pipe, pressure in the pipe, and other safety-related factors.

ONG GOSM 106-1

Subject:

Materials
Investigation of Material Failures

Issued:

03-01-95

Revised: 12-20-01

PURPOSE

To identify and report material or pipeline facilities failures thereby enhancing the prevention
of future occurrences.

REFERENCES

CFR 49: Parts 192.617.

Page
13

SUMMARY

Following are procedures to identify and report material or facilities failures.

Responsibility
Superintendent,
Inspector, Foreman,
Technician,
and Storekeeper

Action
Collect, obtain, and identify any piece of material or pipeline
component that has visible or detected flaws or imperfections in the Lead Gas
quality of the material or facility.

The following types of material or facilities failures, flaws, or imperfections

require reporting:
Longitudinal or circumferential cracks, pits, dents, and gouges.
Cracks or slag penetration in prefabricated or shop produced welds.
Defective fusion joints not due to operator or fusion machine error.
Body or casting cracks or flaws in valves, flanges, regulators, relief
valves, or other manufactured pipeline components.
Poor quality flange gaskets and seals.
Samples of pipe (steel or plastic) should include the damaged, failed, or flawed
portion along with a random length of pipe no less than 18- in length on either side
of failed section.
Samples of flanges, valves, regulators, relief valves, or other manufactured fittings
should include the item itself plus any connecting components that may have
contributed to the failure.
When removing a failed fitting, such as a transition fitting, employ the Inspector,
wet rag technique to minimize the exposure to heat at the plastic-to- Lead Gas
steel connection.
Report all material or facilities failures that are discovered through material
inspections, installation applications, or during pressure testing and qualification to
the staff engineer.
Include in the report all information relative to the failure.
Region Staff Engineer

Determine whether or not an incident resulted from the material failure

To report all in-service material or facilities failures that result in an incident. (See
Procedure 104-6, Incidents--Due to Material or Facilities Failure).
If the material failure was not involved in an incident, determine if formal
investigation could be beneficial.
If so, within ten days of detection of a failure or discovery of a material flaw or
imperfection, assign a defective material identification number to the material
sample. Document the information on Form 767, Failure Report--Material or In-

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14

Place Facility (Figure 1). Continue to follow the reporting procedure as outlined in
Procedure 104-6, Incidents--Due to Material or Facilities Failure.

FORMS

Form 767, Failure Report - Material or In-Place Facility

ONG GOSM 106-1

Subject:

Materials
Investigation of Material Failures

Issued: 03-01-95
Revised 7-31-2014

ONG GOSM 106-1 has been superseded by the ONE Gas standard OKEdis2.1006 Defect Reporting
If in doubt as to which portion of the GOSM or OGS standards are in effect, please seek guidance from any of
the following: your supervisor, Company regulatory compliance specialists, technical training department or
engineering.

ONG GOSM 104-6

Subject:

I Issued:

Incidents/Incident Reporting

03-01-95
Incident ReportingDue to Material or Facilities Failurej Revised: 09-05-12

PURPOSE

To establish guidelines for the investigation and evaluation of accidents/incidents

where the cause may be the result of a material or facilities failure.

REFERENCES

CFR49: Parts 192.605 and 192.617.

Following are:
Procedures for investigating, identifying, handling, and reporting upon
accidents/incidents caused by the in-place failure of materials or the related
pipeline facilities and/or components.
Procedures for the collection and analysis of failed material.

General Statement

The following types of in-place material failures require formal investigation and
laboratory analysis if applicable:
Longitudinal or circumferential cracks in pipe or the body of components.
Cracks in welds.
Defective fusion joints.

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15

 Body or casting cracks or flaws in valves, flanges, regulators, relief valves,

or other manufactured pipeline components.
Material investigations may require in-place investigation by region and/or General
Office staffs. This should be considered before materials are moved or altered.

Responsibility
First Responder,
All Employees
Responsible for
Investigations of
Accidents/Incidents

Action
Follow "Guide for Responding to Accidents/Incidents," Procedure
104-1, as necessary.
Photograph and record pertinent in-place measurements of failed material. Collect
and tag any piece of material or pipeline component that may be related to an
accident or incident.

Samples from a pipeline failure should include the failed or damaged portion of the
pipe along with a suitable length of pipe(s), no less than 24" on either side of the
failure area.
Flanges, valves, regulators, relief valves, or other failed manufactured fittings
should be accompanied by adjoining components that may have contributed to the
failure.
When removing a failed fitting:
Minimize exposure to heat at any plastic-to-steel connection.
Maintain the sample in as near as possible the condition in which it was
found.
Store failed samples in weather-tight buildings.
Limit accessibility to stored, failed material. Region Engineer

Region Engineer
Or Designee

Within three days of the failure, assign a defective material

identification number to each report and tag or identify the material sample. The
numbering system will consist of three parts as follows:
1. The first number is the region identification number where the defective material
was found.
2.

The second number represents the year when the defective material was found.

3.

The third number is the sequence in which the defect was discovered for each
piece during any calendar year.

Example:

West Region found its tenth piece of defective material during

February 1993. The report and defective fitting or pipe should show
the Number 2-93-10.

Page
16

In case of failure, contact division engineering/operations for instruction on where

to send failure samples.
If a sample cannot be transported because of potential damage to it, store in a secure
location in the region and note on the Defect Form.
Do not ship samples that are the result of dig-ins.
Report failures assumed to be caused by inadequate construction techniques to
allow evaluation and revision of technique.

V.

Federal Incident Report - Gas Distribution System - Form PHMSA F 7100.1

ONG submitted two Federal Incident Reports titled "Incident Report - Gas Distribution System"
(Report). Both Reports were submitted on the same day, with the supplemental report being submitted to
correct the original report's Section G5, which indicated the joint failure to be in a welded butt joint. The
supplemental report correctly indicated the joint failure to be in fusion joint.
ONG's Report indicated the failure to be the result of "poor workmanship" in the fusion joint. It
further stated the leak was caused by a lack of fusion in the interior mid-portion of the weld in the
segment of the weld where the crack was located.
The Report indicated one person received injuries requiring inpatient hospitalization. Damages
were estimated to be $509,422 dollars with five residential customers losing gas service due to the
incident.

VI.

Post Incident Measures by Oklahoma Natural Gas Company

Beginning on February 10, 2016, ONG replaced the existing 4-inch FE main with 1,258 feet of 4inch PE pipe and replaced 12 residential service lines and one commercial service line. ONG abandoned
in place the original 1,276 feet of 4-inch FE pipe and 24 feet of 2-inch FE service pipe. The new main
and service lines were pressure tested to 108 psig on February 19, 2016. All of the residences, with the
exception of the residences located at 12413, 12501, 12505, 12509, and 12515 Whispering Hollow Drive,
had gas service restored.
On March 3, 2016, ONG issued a statement concerning a complete review of leakage surveys and
repairs conducted on all PE mains and service lines. The first review began in the Walnut Creek
subdivision. ONG is currently conducting a systematic records review and joint sampling in its
Oklahoma service territory. ONG expects the review to be completed by year end. ONG will perform
the remediation necessary to maintain the safety and reliability of its system.

VII.

Probable Cause

The Oklahoma Corporation Commission's Pipeline Safety Department has determined the
probable cause of the January 2, 2016, natural gas explosion at 12505 Whispering Hollow Drive,
Oklahoma City, Oklahoma, was the failure of the 4-inch FE main in the fusion joint. The fusion joint had
inadequate fusion in the interior mid-portion of the butt fusion joint.

Page
17

Contributing to the incident was ONG's failure to analyze the previous eight joint failures on the
1,269 feet of 4-inch PE main in the Walnut Creek Subdivision. Based on repair records, all previous joint
failures occurred in the fusion butt joints. There were no records indicating that any action, other than
repairing the existing leak, was taken. There were no actions taken to determine the cause of the failed
fusion joints and eliminate or minimize the reoccurrence of future butt fusion joint failures.
Additionally, the failure to properly investigate the odor complaint on the afternoon of January 1,
2016, further contributed to the incident. Company procedures require the investigation of a gas leak to
pin-point the gas leak and determine the migration pattern. This is accomplished by conducting a series
of bar-hole leak surveys in all directions around the suspected leak location and expanding the bar-hole
survey in a circular pattern to determine the extent of gas migration.
Technician I only conducted bar-hole surveys along the customer's fuel line running from the gas
meter to the point where the fuel line entered the residence, beside the gas meter to the south and north
and along where he thought the service line ran from the gas meter to the gas main. Had Technician 1
followed ONG procedures, the precise location of the leak would have been identified, resulting in
additional information being made available to judge the severity of the situation.

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18

Exhibit B
Notice of Probable Violation

BOB ANTHONY
Commissioner

TODD I-IIETT
Commissioner

DANA MURPHY
Commissioner

OKLAHOMA
CORPORATiON COMMISSION

Transportation Division
Pipeline Safety Department

P.O. BOX 52000

OKLAHOMA CITY, OKLAHOMA 73152-2000

2101

North Lincoln Blvd, Room 231

Www.occeweb.com

Office:
FAX:

Oklahoma City, OK 73105

(405) 521-2268
(406) 521-3455

CERTIFIED RECEIPT REQUESTED

NOTICE OF PROBABLE VIOLATION
May 21, 2016

Mr. Kent Shortridge, Vice President

Oklahoma Natural Gas Company
4901 N. Santa Fe
Oklahoma City, OK 73118
Inspection Report #
Type of Inspection:

PLS-NG-16-222
Incident

Dear Mr. Shortridge:

Pursuant to the authority granted to the Oklahoma Corporation Commission under Title 52 of the
Oklahoma Statutes Section 5, Title 63 of the Oklahoma Statutes Section 142.13, and the Oklahoma
Administrative Code (OAC) 165:20-13-12, inspectors from the Oklahoma Corporation Commission's
Pipeline Safety Department conducted an onsite incident investigation which occurred on January 2,
2016 at 12505 Whispering Hollow Drive, Oklahoma City, Oklahoma. As a result of our inspection,
Oklahoma Natural Gas Company (ONG) is in probable violation of the following:
192.605 Procedural manual for operations, maintenance, and emergencies.
(a)
General.
Each operator shall prepare and follow for each pipeline, a manual of written
procedures for conducting operations and maintenance activities and for emergency response...
192.615 Emergency plans.
(a)
Each operator shall establish written procedures to minimize the hazard resulting from a gas
pipeline emergency. At a minimum, the procedures must provide for the following;
(1)
Receiving, Identifying, and classifying notices of events which require immediate
response by the operator.
During the Investigation of the incident at 12505 Whispering Hollow Drive, it was determined the
Customer Service Technician dispatched to investigate an odor complaint at 12501 Whispering Hollow
Drive, on January 1, 2016, failed to follow ONG's written procedure for investigating the complaint
ONG's Service Order Procedure 301 Form 11015 issued 01195 and revised 11/08, required:
a.

'Perform a bar hole survey to pinpoint any possible leaks. Use a CGI to check in all directions
around the leak area to determine if there is migration. Check around all structures, over the
buried pipelines in the area, sewer, manhole covers and at any other source where gas may
migrate through or to.'

Oklahoma Natural Gas Company

12505 Whispering Hollow Drive - Incident
Page #2
it is important to determine and document the full extent of a leak migration pattern. Check the
area of leakage in a minimum of four directions until zero (0% gas) readings are obtained.
Document the area of leak migration on the Pipeline leak and Repair (PL&R) form (upstream of
meter) and/or Service Order (downstream of meter).
In the process of Investigating the odor complaint at 12501 Whispering Hollow Drive in Oklahoma City,
the technician discovered what he classified as a class two leak two feet west of the gas meter at 12505
Whispering Hollow Drive. Documentation provided by ONG, indicated the Customer Service Technician
did not conduct the Bar Hole Survey at 12505 Whispering Hollow Drive as required by ONG's procedure.
The technician only surveyed the service line, the customer's yard line, and four corners of the customers
home. There was no documentation to substantiate the technician conducted a survey over all buried
pipelines (main), sewer, or manhole covers and at any other source where gas may migrate through and
determine the migration pattern as required by your procedures. The post accident investigation revealed
the gas leak was actually 22' south of the suspected leak area and the gas migrated along the main. His
failure to perform the leak investigation as required by ONG's Service Order Procedure 301, allowed a
potentially hazardous leak to go undetected.
ONG is in probable violation of 192.605(a) and 192.615(a) for failing to follow the Code and your
written procedures for investigating a gas odor complaint Please provide this office with an action plan to
ensure written procedures are followed.
192.813 Continuing Surveillance.
Each operator shall have a procedure for continuing surveillance of its facilities to determine and
(a)
take appropriate action concerning changes in class location, failures, leakage history, corrosion,
substantial changes in cathodic protection requirements, and other unusual operating and
maintenance conditions.
If a segment of pipeline is determined to be in unsatisfactory condition but no immediate hazard
(b)
exists, the operator shall initiate a program to recondition or phase out the segment involved, or, if
the segment cannot be reconditioned or phased out, reduce the maximum allowable operating
pressure in accordance with 192.619(a) and (b).
192.617 lnvestkiation of faIlures.
Each operator shall establish procedures for analyzing accidents and failures, including the selection of
samples of the failed facility or equipment for laboratory examination, where appropriate, for the purpose
of determining the causes of the failure and minimizing the possibility of a recurrence.
The Code and your (3OSM 505-10 and OKEdis2.1810 require an operator to develop and carry out a
program for the continuing surveillance of its facilities to determine and take appropriate action
concerning failures and to conduct appropriate laboratory examinations to analyze failed facilities to
minimize the possibility of a recurrence.
Under Job Order Number 525-15-20, ONG installed 1269' of 4" butt fused polyethylene pipe between the
dates of June 15 and August 11, 1983, in the Walnut Creek Addition. The first failure of the pipe occurred
on December 21, 1983, with leak repair records indicating the leak was In the butt fusion of the joint The
second failure occurred on January 24, 1985, with the leak repair records indicating the leak was caused
by the fusion joint pulling apart. Since its installation, the 4" butt fused polyethylene main has experienced
a total of 10 documented leaks with nine leaks being repaired. All nine of the leak repairs were classified
as having leaks in the fusion joint or the fusion joint pulling apart With the exception of the leak at 12505
Whispering Hollow Drive, there was no documentation to substantiate any of the leaks were subjected to
a laboratory examination to determine the cause of leaking. Additionally, during the life of the pipeline,
there was no documentation to Indicate ONG ever reviewed the leak history of the pipeline to determine
its suitability for service.
ONG Is in probable violation of 192.613 and 192.617 for failing to follow the Code and your written
procedures for continuing surveillance of their facilities and the analyzing of failures to minimize their

Oklahoma Natural Gas Company

12505 Whispering Hollow Drive - Incident
Page #3
recurrence. Please provide this office with an action plan to ensure ONG's written procedures are
followed.
Pursuant to OAC 165:20-13-I, for any violation of Commission rules in Subchapter 5, the Commission
may issue an order pursuant to 17 O.S. Section 1 et seq, fining an operator up to ten thousand dollars
($10,000) per day plus prosecution costs for each violation for each day the violation continues, provided
the maximum penalty shall not exceed five hundred thousand dollars ($500,000) for any related series of
violations.
Pursuant to in OAC 165:20-13-13, this letter serves as your notification of the probable violations noted
during our investigation. Pursuant to OAC 165:20-13-14Oklahorna Natural Gas Company has 30 days
from receipt of this notice to respond, indicating the violations described above are violations and have
been corrected; acknowledging the violations and requesting a time extension to correct the
violations;objecting to the probable violations; or requesting a conference under 165:20-13-16. Failure to
respond to this notice may subject your company to further Commission action which could result in a civil
penalty as prescribed in OAC 165:20-13-1.
Sincerely,

Dennis Fothergill
Regulatory Program Manager
Pipeline Safety Department
xc:

Inspection File
DF CF