# TARGA RESOURCES OPERATING LLC — Notice of Probable Violation

- **operation:** document
- **citation:** CPF 320196003
- **title:** TARGA RESOURCES OPERATING LLC — Notice of Probable Violation
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2019-09-26
- **effective on:** Not available
- **summary:** CLOSED notice of probable violation citing 194.107(c)(1)(ix), 195.264(a), 195.264(b)(1)(i).
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320196003
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320196003
**body:**

Notice of Probable Violation involving TARGA RESOURCES OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 194.107(c)(1)(ix),  195.264(a),  195.264(b)(1)(i). The case was opened on 2019-09-26 and is reported as closed as of 2020-06-03. Proposed civil penalty: $22,800. Assessed civil penalty: $22,800. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320196003_Closure Letter_06032020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196003/320196003_Closure%20Letter_06032020.pdf

320196003_Closure Letter_06032020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196003/320196003_Closure%20Letter_06032020_text.pdf

320196003_Final Order_04242020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196003/320196003_Final%20Order_04242020.pdf

320196003_Final Order_04242020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196003/320196003_Final%20Order_04242020_text.pdf

320196003_NOPV PCP PCO_09262019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196003/320196003_NOPV%20PCP%20PCO_09262019.pdf

320196003_NOPV PCP PCO_09262019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196003/320196003_NOPV%20PCP%20PCO_09262019_text.pdf

320196003_Operator Response to Notice (REVISED)_02042020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196003/320196003_Operator%20Response%20to%20Notice%20(REVISED)_02042020.pdf

320196003_Operator Response to Notice_10252019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196003/320196003_Operator%20Response%20to%20Notice_10252019.pdf

320196003_Closure Letter_06032020_text.pdf

VIA ELECTRONIC MAIL TO: and gjohnson@targaresources.com
mmeloy@targaresources.com , jpabon@targaresources.com
June 3, 2020
Mr. Matthew J. Meloy
Chief Executive Officer
Targa Resources Operating, LLC
811 Louisiana, Suite 2100
Houston, Texas 77002
RE: CPF 3-2019-6003
Dear Mr. Meloy:
On April 24, 2020, the Pipeline and Hazardous Materials Administration (PHMSA) issued to
Targa Resources Operating, LLC a Final Order in the above referenced case. This Order
included a Compliance Order and Civil Penalty assessment. Based on our review of the
documentation provided and confirmation of payment of the civil penalty, it has been determined
that you have complied with the terms of the Order.
Accordingly, this case is now closed and no further action is contemplated with respect to the
matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
Copy:
Julie Pabon, Associate General Counsel & Director, Targa Resources
Gregg Johnson, Director of Pipeline Compliance, Targa Resources

320196003_Final Order_04242020_text.pdf

April 24, 2020
VIA EMAIL TO: mmeloy@targaresources.com
Mr. Matthew J. Meloy
Chief Executive Officer
Targa Resources Operating, LLC
811 Louisiana, Suite 2100
Houston, Texas 77002
Re: CPF No. 3-2019-6003
Dear Mr. Meloy:
Enclosed please find the Final Order issued in the above-referenced case. It makes findings of
violation, assesses a civil penalty of $22,800, and specifies actions that need to be taken by Targa
Resources Operating, LLC, a subsidiary of Targa Resources Corporation, to comply with the
pipeline safety regulations. This also acknowledges receipt of payment of the full penalty
amount, by wire transfer, dated November 15, 2019. When the terms of the compliance order
have been completed, as determined by the Director, Central Region, this enforcement action
will be closed. Service of the Final Order by electronic mail is deemed complete upon
transmission and acknowledgement of receipt, or as otherwise provided under 49 C.F.R. § 190.5.
Thank you for your cooperation in this matter.
Sincerely,
Alan K. Mayberry
Associate Administrator
for Pipeline Safety
Enclosure
cc: Mr. Allan C. Beshore, Director, Central Region, Office of Pipeline Safety, PHMSA
Mr. Gregg Johnson, Director of Pipeline Compliance, Targa Resources Corporation,
gjohnson@targaresources.com
Ms. Julie Pabon, Senior Counsel, Targa Resources Corporation, jpabon@targaresources.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 )
Targa Resources Operating, LLC, ) CPF No. 3-2019-6003
a subsidiary of Targa Resources Corporation, )
)
)
)
Respondent. )
__________________________________________)
FINAL ORDER
From June 26-28, July 24-26, and July 31-August 2, 2018, pursuant to 49 U.S.C. § 60117,
representatives 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 Targa Resources Operating, LLC (Targa or Respondent), including its Saddle Butte
crude oil pipeline system in North Dakota. Targa is a subsidiary of Targa Resources
Corporation,1 which provides midstream services in North America.2
As a result of the inspection, the Director, Central Region, OPS (Director), issued to Respondent,
by letter dated September 26, 2019, a Notice of Probable Violation, Proposed Civil Penalty, and
Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the Notice
proposed finding that Targa had violated 49 C.F.R. §§ 194.107(c)(1)(ix) and 195.264(b)(1)(i)
and proposed assessing a civil penalty of $22,800 for one of the alleged violations. The Notice
also proposed ordering Respondent to take certain measures to correct the alleged violations.
Targa Resources Corp. responded on Respondent’s behalf by letter dated October 25, 2019
(Response).3 The company did not contest one of the allegations of violation and paid the
proposed civil penalty of $22,800. Targa contested the other alleged violation and
accompanying proposed compliance actions. Respondent did not request a hearing and therefore
has waived its right to one.
1 Targa Resources Corporation, 10-K, 2019 Annual Report, filed February 20, 2020, available at
https://ir.targaresources.com/sec-filings/sec-filing/10-k/0001564590-20-005592 (last accessed on April 8, 2020).
2 Targa Resources Corporation website, available at https://www.targaresources.com/about-us/overview (last
accessed on April 8, 2020).
3 The Response also responded to a separate Warning Letter, CPF 3-2019-6004W, and Notice of Amendment, CPF
3-2019-6005M. Regarding CPF 3-2019-6004W, pursuant to § 190.205, an “operator may submit a response to a
warning, but is not required to. An adjudication under this subpart to determine whether a violation occurred is not
conducted for warnings.” Regarding CPF 3-2019-6005M, that matter was closed November 26, 2019.



CPF No. 3-2019-6003
Page 2
FINDINGS OF VIOLATION
The Notice alleged that Respondent violated 49 C.F.R. Parts 194 and 195, as follows:
Item 1: The Notice alleged that Respondent violated 49 C.F.R. § 194.107(c)(1)(ix), which states:
§ 194.107 General response plan requirements.
(a) ...
(c) Each response plan must include:
(1) A core plan consisting of-
(i) ...
(ix) Drill program-an operator will satisfy the requirement for a drill
program by following the National Preparedness for Response Exercise
Program (PREP) guidelines. An operator choosing not to follow PREP
guidelines must have a drill program that is equivalent to PREP. The
operator must describe the drill program in the response plan and OPS will
determine if the program is equivalent to PREP.
The Notice alleged that Respondent violated 49 C.F.R. § 194.107(c)(1)(ix) by failing to satisfy
the requirements for a drill program which follow PREP Guidelines, Section 5.1, Drill: Qualified
Individual (QI) Notification, or the equivalent. With regard to frequency, Section 5.1 specifies
that QI notification drills must be conducted “as indicated by the response plan and, at a
minimum, consistent with the triennial cycle (quarterly).” Specifically, Targa did not conduct QI
notification drills each quarter during the three-year period from 2015 through 2017. A total of
twelve quarterly notifications drills were not conducted. Targa provided no evidence that it
followed a drill program that is equivalent to that set forth in PREP.
Respondent did not contest this allegation of violation. Accordingly, based upon a review of all
of the evidence, I find that Respondent violated 49 C.F.R. § 194.107(c)(1)(ix) by failing to
satisfy the requirements for a drill program which follow PREP Guidelines, Section 5.1, Drill: QI
Notification, or the equivalent.
Item 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.264(b)(1)(i), which states:
§ 195.264 Impoundment, protection against entry, normal/emergency
venting or pressure/vacuum relief for aboveground breakout tanks.
(a) A means must be provided for containing hazardous liquids in the
event of spillage or failure of an aboveground breakout tank.
(b) After October 2, 2000, compliance with paragraph (a) of this section
requires the following for the aboveground breakout tanks specified:
(1) For tanks built to API Spec 12F, API Std 620, and others (such as
API Std 650 (or its predecessor Standard 12C), the installation of
impoundment must be in accordance with the following section of NFPA-
30 (2008 edition) (incorporated by reference per § 195.3);
(i) Impoundment around a breakout tank must be installed in accordance
with section 22.11.2.



CPF No. 3-2019-6003
Page 3
The Notice alleged that Respondent violated 49 C.F.R. § 195.264(b)(1)(i) by failing to satisfy the
requirements of Section 22.11.2 of NFPA-30 (2008 edition) regarding impoundment and ground
slope around the breakout tanks. Specifically, the Notice alleged that the control of drainage of
Tanks 200 and 210 at the Johnson’s Corner facility and Tank 3000 at the New Town facility was
not accessible under fire conditions from outside the containment area as required by section
22.11.2.7.1 of NFPA-30 (2008 edition). Section 22.11.2.7.1 states “[c]ontrol of drainage shall be
accessible under fire conditions from outside the dike.” Additionally, field inspection of Tank
210 at the Johnson’s Corner facility identified an area that did not have a slope of not less than
one percent away from the tank as required by section 22.11.2.1 of NFPA-30 (2008 edition).
Section 22.11.2.1 states “[a] slope of not less than 1 percent away from the tanks shall be
provided for at least 50 feet or to the dike base, whichever is less.”
In its Response, Targa contested the allegation of violation and requested that it be withdrawn.
Targa stated that access to the valve controlling the drainage meets the “intent” of the
requirement in NFPA-30. In reference to the access to control drainage from outside the
containment requirement, Targa argued that NFPA-30 does not specify the means to access the
valve controlling the drainage. It stated that at the Johnson's Corner facility, the drain valve is
accessed via a platform built above the containment dike and accessed from outside the dike.
Targa explained that “The current installation configuration avoids the very realistic scenario of
filling the containment drainpipe up with water, freezing, and damaging the integrity of the
drainpipe/drain valve due to ice formation…. personnel do not have to climb inside the dike
(beneath the top of [the] containment wall) to access the valve… [and a] platform is provided for
personnel to access the valve actuator without walking into the dike (beneath the top of [the]
containment wall).”4
I find that Targa has not met the requirements § 195.264(b)(1)(i) by failing to follow NFPA-30,
22.11.2.7.1. Section 22.11.2.7.1 specifically focused on access “under fire conditions.” While
Targa’s set up with the valve controlling drainage can be accessed from outside the dike, its
position is not conducive with access during fire conditions. The valve is placed on a platform
that runs away from the top of the dike, with the valve positioned directly over the dike.5 If there
was a fire in the dike, an operator would need to stand directly over the dike in order to access
the valve. Likewise, Targa’s explanation of its “current installation configuration” focuses on
avoiding scenarios involving water, freezing, and ice formation- not fire conditions as required in
NFPA-30.
Targa also contested the allegation that its containment was required to have a slope of not less
than one percent away from the tank. Targa argued that because this requirement is part of
Subpart D, Construction, requirements that address maintenance of the impoundment are
inapplicable. Targa therefore concluded that there was no regulatory obligation to maintain a
one percent slope after construction was completed.
Regarding the slope away from the tank, I find Targa in violation of § 195.264(b)(1)(i) by failing
4 Response, at 3.
5 See Pipeline Safety Violation Report (Violation Report), (September 26, 2019) (on file with PHMSA), at 19-12
(photographs of access platforms).



CPF No. 3-2019-6003
Page 4
to meet the requirements in NFPA-30. In this case, the area surrounding the tank was observed
during the inspection after excavation/construction work related to the tank.6 Specifically, Targa
was engaged in work for the attachment of a conduit to the side of the concrete tank foundation
during which the operator removed soil creating a slope towards the tank. Section 195.264 and
other regulations in Subpart D prescribe minimum requirements not only for constructing new
pipelines but “for relocating, replacing, or otherwise changing existing pipeline systems.”
§ 195.200. In order to remain in compliance with § 195.264(b)(1)(i), Targa was required to
restore the slope away from the tank at the conclusion of this work.
Targa’s argument that it no longer had a regulatory obligation to comply with § 195.264(b)(1)(i)
because it “does not address maintenance requirements of the impoundment nor are the
requirements included in Subpart F Operations and Maintenance of Part 195” does not stand up
under scrutiny. Targa was engaged in construction work, and was required to remediate the
noncompliant condition created during that activity to ensure that the area around the tank had
the required one percent slope.
Accordingly, after considering all of the evidence, I find that Respondent violated 49 C.F.R.
§ 195.264(b)(1)(i) by failing to satisfy the requirements of Section 22.11.2 of NFPA-30 (2008
edition) regarding impoundment and ground slope around the breakout tanks.
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 not to exceed
$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any
related series of violations.7 In determining the amount of a civil penalty under 49 U.S.C.
§ 60122 and 49 C.F.R. § 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; and the good faith of Respondent
in attempting to comply with the pipeline safety regulations. 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 $22,800 for the violation cited above.
Item 1: The Notice proposed a civil penalty of $22,800 for Respondent’s violation of 49 C.F.R.
§ 194.107(c)(1)(ix), for failing to satisfy the requirements for a drill program which follow PREP
Guidelines, Section 5.1, Drill: QI Notification, or the equivalent. Targa neither contested the
allegation nor presented any evidence or argument justifying elimination of the proposed
penalty. Accordingly, having reviewed the record and considered the assessment criteria, I assess
6 See Violation Report, at 22 (photograph of the area around the tank without a one percent slope).
7 These amounts are adjusted annually for inflation. See 49 C.F.R. § 190.223.



CPF No. 3-2019-6003
Page 5
Respondent a civil penalty of $22,800 for violation of 49 C.F.R. § 194.107(c)(1)(ix), which
amount was paid in full by wire transfer on November 15, 2019.
COMPLIANCE ORDER
The Notice proposed a compliance order with respect to Item 2 in the Notice for the violation of
49 C.F.R. § 195.264(b)(1)(i). 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.
With regard to the violation of § 195.264(b)(1)(i) (Item 2), Respondent argued the compliance
terms should be withdrawn because no violation was committed. I have rejected this argument
above. Therefore, I find that Targa must complete the proposed compliance actions.
Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 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 § 195.264(b)(1)(i) (Item 2), Respondent must:
a. Make alterations to the drainage control system so it can be accessed
during fire conditions;
b. c. Alter the slope away from the tank as required by § 195.264(b)(1)(i); and
Complete the above items within 90 days after the 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.
It is requested (not mandated) 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 the administrative assessment of civil penalties
not to exceed $200,000, as adjusted for inflation (49 C.F.R. § 190.223), 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.
Under 49 C.F.R. § 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, no later than 20 days after receipt of service of this
Final Order by Respondent. Any petition submitted must contain a statement of the issue(s) and
meet all other requirements of 49 C.F.R. § 190.243. The filing of a petition automatically stays



CPF No. 3-2019-6003
Page 6
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
C.F.R. § 190.5.
April 24, 2020
___________________________________ __________________________
Alan K. Mayberry Date Issued
Associate Administrator
for Pipeline Safety

320196003_NOPV PCP PCO_09262019_text.pdf

NOTICE OF PROBABLE VIOLATION
PROPOSED CIVIL PENALTY
and
PROPOSED COMPLIANCE ORDER
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
September 26, 2019
Mr. Joe Bob Perkins
Chief Executive Officer
Targa Resources Operating, LLC
811 Louisiana, Suite 2100
Houston, Texas 77002
CPF 3-2019-6003
Dear Mr. Perkins:
On June 26th-28th, July 24th-26th and July 31st-August 2nd of 2018, representatives of the
Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601
of 49 United States Code (U.S.C.) inspected facilities and records of your Saddle Butte crude
oil pipeline system in North Dakota.
As a result of the inspection, it is alleged that you have committed probable violations of the
Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items
inspected and the probable violations are:



1. §194.107 General response plan requirements.
(a) . . .
(c) Each response plan must include:
(1) A core plan consisting of-
(i) . . .
(ix) Drill program—an operator will satisfy the requirement for a drill program
by following the National Preparedness for Response Exercise Program (PREP)
guidelines. An operator choosing not to follow PREP guidelines must have a drill
program that is equivalent to PREP. The operator must describe the drill
program in the response plan and OPS will determine if the program is
equivalent to PREP.
PREP Guidelines, Section 5.1, Drill: Qualified Individual (QI) Notification
Frequency: As indicated by the response plan and, at a minimum, consistent with
the triennial cycle (quarterly).
Targa Resources Operating, LLC (Targa) failed to satisfy the requirements for a drill
program which follow PREP Guidelines, Section 5.1, Drill: QI Notification.1
Specifically, Targa did not conduct QI notification drills each quarter during the three
year period from 2015 through 2017. A total of twelve (12) quarterly notifications
drills were not conducted.
2. §195.264 Impoundment, protection against entry, normal/emergency venting or
pressure/vacuum relief for aboveground breakout tanks.
(a) A means must be provided for containing hazardous liquids in the event of
spillage or failure of an aboveground breakout tank.
(b) After October 2, 2000, compliance with paragraph (a) of this section requires
the following for the aboveground breakout tanks specified:
(1) For tanks built to API Spec 12F, API Std 620, and others (such as API Std
650 (or its predecessor Standard 12C)), the installation of impoundment must be
in accordance with the following section of NFPA-30 (2008 edition)(incorporated
by reference per §195.3);
(i) Impoundment around a breakout tank must be installed in accordance with
section 22.11.2.
Targa failed to satisfy the requirements of Section 22.11.2 of NFPA-30 (2008 edition)
regarding impoundment and ground slope around the breakout tanks.
PHMSA’s field inspection of Tanks 200 & 210 at Targa Resources Johnson’s Corner
facility and Tank 3000 at the New Town facility found that control of drainage was not
accessible under fire conditions from outside the containment area as required per
1 Targa provided no evidence that it followed a drill program that is equivalent to that set forth in PREP.
2



section 22.11.2.7.1 of NFPA-30 (2008 edition). Section 22.11.2.7.1 states “[c]ontrol
of drainage shall be accessible under fire conditions from outside the dike.”
Additionally, field inspection of Tank 210 at Targa Resources Johnson’s Corner
facility identified an area that did not have a slope of not less than 1% away from the
tank as required per section 22.11.2.1 of NFPA-30 (2008 edition). Section 22.11.2.1
states “[a] slope of not less than 1 percent away from the tanks shall be provided for at
least 50 feet or to the dike base, whichever is less”.
Proposed Civil Penalty
Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to
exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465
for a related series of violations. For violation occurring on or after November 27, 2018 and
before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day,
with a maximum penalty not to exceed $2,132,679. For violation occurring on or after
November 2, 2015 and before November 27, 2018, the maximum penalty may not exceed
$209,002 per violation per day, with a maximum penalty not to exceed $2,090,022. For
violations occurring prior to November 2, 2015, the maximum penalty may not exceed
$200,000 per violation per day, with a maximum penalty not to exceed $2,000,000 for a
related series of violations. . The Compliance Officer has reviewed the circumstances and
supporting documentation involved for the above probable violation(s) and has recommended
that you be preliminarily assessed a civil penalty of $22,800 as follows:
Item number PENALTY
1 $22,800
Proposed Compliance Order
With respect to item 2 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials
Safety Administration proposes to issue a Compliance Order to Targa Resources Operating,
LLC. Please refer to the Proposed Compliance Order, which is enclosed and made a part of
this Notice.
Response to this Notice
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
3



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).
Following the receipt of this Notice, you have 30 days to submit written comments, or request
a hearing under 49 CFR § 190.211. 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 you are responding to this
Notice, we propose that you submit your correspondence to my office within 30 days from
receipt of this Notice. This period may be extended by written request for good cause.
In your correspondence on this matter, please refer to CPF 3-2019-6003 and, for each
document you submit, please provide a copy in electronic format whenever possible.
Sincerely,
Allan C. Beshore
Director, Central Region, Office of Pipeline Safety
Pipeline and Hazardous Materials Safety Administration
Enclosures: Proposed Compliance Order
Response Options for Pipeline Operators in Compliance Proceedings
Copy:
Mr. Clark White
Executive VP Engineering and Ops
Targa Resources Operating, LLC
811 Louisiana St., Suite 2100
Houston, TX 77002
4



PROPOSED COMPLIANCE ORDER
Pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety Administration
(PHMSA) proposes to issue to Targa Resources Operating, LLC a Compliance Order
incorporating the following remedial requirements to ensure the compliance of Targa
Resources Operating, LLC with the pipeline safety regulations:
1. 2. 3. In regard to Item Number 2 of the Notice pertaining to (a) the provision for the control
of drainage of open dike impoundment areas around tanks, the operator must make
alterations to the drainage control system so it can be accessed during fire conditions;
and (b) the provision that a slope of not less than 1% away from the tank shall be
provided for at least 50 feet, the operator must alter the slope away from the tank as
required by §195.264(b)(1)(i).
The operator must complete the above item within 90 days after the receipt of the Final
Order.
It is requested (not mandated) that Targa Resources Operating, LLC maintain
documentation of the safety improvement costs associated with fulfilling this
Compliance Order and submit the total to Allan C. Beshore, Director, Central Region,
Pipeline and Hazardous Materials Safety Administration. 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.
5
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