{"operation":"document","citation":"CPF 320196005M","title":"TARGA RESOURCES OPERATING LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2019-09-26","effective_on":null,"summary":"CLOSED notice of amendment citing 195.452(f)(1), 195.565, 195.573(d), 195.579(d).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-320196005m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-320196005m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-320196005m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/320196005M","body":"Notice of Amendment involving TARGA RESOURCES OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 195.452(f)(1),  195.565,  195.573(d),  195.579(d). The case was opened on 2019-09-26 and is reported as closed as of 2019-11-26. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n320196005M_Closure Letter_11262019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196005M/320196005M_Closure%20Letter_11262019.pdf\n\n320196005M_Closure Letter_11262019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196005M/320196005M_Closure%20Letter_11262019_text.pdf\n\n320196005M_Notice of Amendment_09262019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196005M/320196005M_Notice%20of%20Amendment_09262019.pdf\n\n320196005M_Notice of Amendment_09262019_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196005M/320196005M_Notice%20of%20Amendment_09262019_text.pdf\n\n320196005M_Operator Response to Notice_10252019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320196005M/320196005M_Operator%20Response%20to%20Notice_10252019.pdf\n\n320196005M_Closure Letter_11262019_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 26, 2019\nMr. Joe Bob Perkins\nChief Executive Officer\nTarga Resources Operating, LLC\n811 Louisiana, Suite 2100\nHouston, TX 77002\nCPF 3-2019-6005M\nDear Mr. Perkins:\nOn June 26-28, July 24-26, and July 31-August 2, 2018, representatives from the Pipeline and\nHazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United\nStates Code, conducted an on-site pipeline safety inspection of Targa Resources Operating,\nLLC’s (Targa) procedures for Operations & Maintenance, Damage Prevention, Public\nAwareness, Operator Qualifications, Integrity Management and Emergency Response in\nWatford City, ND. As a result of the inspection, Targa was issued a Notice of Amendment on\nSeptember 26, 2019, which proposed and acknowledged the amendment of your procedures.\nMy staff reviewed the amended procedures, and it appears that the inadequacies outlined in\nthis Notice of Amendment were corrected prior to the Notice.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank\nyou for your cooperation.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, OPS\nPipeline and Hazardous Materials Safety Administration\n\n320196005M_Notice of Amendment_09262019_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 26, 2019\nMr. Joe Bob Perkins\nChief Executive Officer\nTarga Resources Operating, LLC\n811 Louisiana, Suite 2100\nHouston, Texas 77002\nCPF 3-2019-6005M\nDear Mr. Perkins:\nOn June 26-28, July 24-26, and July 31-August 2, 2018, representatives of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United\nStates Code inspected Targa Resources Operating, LLC’s (Targa) procedures for Operations\n& Maintenance, Damage Prevention, Public Awareness, Operator Qualifications, Integrity\nManagement and Emergency Response in Watford City, North Dakota.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTarga’s procedures, as described below:\n1. §195.452 Pipeline integrity management in high consequence areas.\n(a) . . .\n(f) What are the elements of an integrity management program? An integrity\nmanagement program begins with the initial framework. An operator must\ncontinually change the program to reflect operating experience, conclusions\ndrawn from results of the integrity assessments, and other maintenance and\nsurveillance data, and evaluation of consequences of a failure on the high\nconsequence area. An operator must include, at minimum, the following element\nin its written integrity management program:\n(1) A process for identifying which pipeline segments could affect a high\nconsequence area; . . .\nTarga’s Integrity Management Program (IMP) was inadequate because it did not provide a\nprocess for when the identification of which pipeline segments that could affect a high\nconsequence area (HCA) should occur. At the time of the inspection, Targa’s IMP\n\n\n\nprocedures allowed a pipeline segment to begin operations before the identification of pipeline\nsegments that could affect a HCA was completed.\nAfter the inspection, Targa amended its IMP procedures under Section 1.2 – Delineation of\nHCA Boundaries to state, “Pipelines constructed or converted after May 29th, 2001 shall be\nincluded in the program on the date the pipeline begins operation.” An amendment was sent\nto PHMSA via email on August 8, 2018. PHMSA reviewed the amended procedures and\nfound that they satisfactorily meet the requirement of §195.452(f)(1). Therefore, no further\naction is required to correct the identified procedural deficiency in Targa’s IMP.\n2. §195.565 How do I install cathodic protection on breakout tanks?\nAfter October 2nd, 2000, when you install cathodic protection under §195.563(a)\nto protect the bottom of an aboveground breakout tank of more than 500 barrels\n79.49m3 capacity built to API Spec 12F (incorporated by reference, see §195.3),\nAPI Std 620 (incorporated by reference, see §195.3), or API Std 650’s\npredecessor, Standard 12C, you must install the system in accordance with\nANSI/API RP 651 (incorporated by reference, see §195.3). However, you don't\nneed to comply with ANSI/API RP 651 when installing any tank for which you\nnote in the corrosion control procedures established under §195.402(c)(3) why\ncomplying with all or certain provisions of ANSI/API RP 651 is not necessary for\nthe safety of the tank.\nTarga’s Operations and Maintenance (O&M) manual was inadequate because it did not have a\nprocedure requiring cathodic protection on breakout tanks that are installed in accordance with\nANSI/API RP 651. After the inspection, Targa amended its Liquid Pipeline Corrosion\nControl procedure to address this deficiency. In an email to OPS dated August 18, 2018,\nTarga provided its revised “Liquid Pipeline Corrosion Control Procedures - Reference:\n195.565”, which requires cathodic protection on breakout tanks to be installed in accordance\nwith ANSI/API RP 651. This amendment to Targa’s procedure satisfactorily meets the\nrequirement of §195.565. Therefore, no further action is required.\n3. §195.573 What must I do to monitor external corrosion control? – Breakout\nTanks\n(d) Breakout tanks. You must inspect each cathodic protection system used to\ncontrol corrosion on the bottom of an aboveground breakout tank to ensure that\noperation and maintenance of the system are in accordance with API RP 651\n(incorporated by reference, see § 195.3). However, this inspection is not required\nif you note in the corrosion control procedures established under §195.402(c)(3)\nwhy complying with all or certain operation and maintenance provisions of API\nRP 651 is not necessary for the safety of the tank.\n2\n\n\n\nTarga’s O&M manual was inadequate because it did not have a procedure requiring details for\nwhen and how cathodic protection systems would be inspected on breakout tanks. After the\ninspection, Targa amended its “Liquid Pipeline Corrosion Control Procedures – Reference:\n195.573” to address this deficiency. In an email to OPS on August 8, 2018, Targa submitted\nits revised procedures detailing when and how cathodic protection systems are to be inspected\non breakout tanks. This amendment to Targa’s procedure satisfactorily meets the requirement\n§195.573(d). Therefore, no further action is required.\n4. §195.579 What must I do to mitigate internal corrosion?\n(d) Breakout tanks. After October 2, 2000, when you install a tank bottom lining\nin an aboveground breakout tank built to API Spec 12F (incorporated by\nreference, see §195.3, API Std 620 (incorporated by reference, see §195.3), API\nStd 650 (incorporated by reference, see §195.3), or API Std 650's predecessor,\nStandard 12C, you must install the lining in accordance with API RP 652\n(incorporated by reference, see §195.3). However, you don't need to comply with\nAPI RP 652 when installing any tank for which you note in the corrosion control\nprocedures established under §195.402(c)(3) why compliance with all or certain\nprovisions of API RP 652 is not necessary for the safety of the tank.\nTarga’s O&M manual was inadequate because it did not have a procedure that required when\ninstalling a tank bottom lining in an aboveground breakout tank built to API Std. 650 to be\ninstalled in accordance with API RP 652. After the inspection, Targa amended its “Liquid\nPipeline Corrosion Control Procedures – Reference 195.579” to address this deficiency and\nsubmitted this revised procedure to OPS vis email on August 8, 2018. OPS reviewed the\nrevised procedure and found it satisfactorily meets the requirement of §195.579(d).\nTherefore, no further action is required.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed\nas part of this Notice is a document entitled Response Options for Pipeline Operators in\nCompliance Proceedings. Please refer to this document and note the response options. Be\nadvised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies\nfor confidential treatment under 5 U.S.C. 552(b), along with the complete original document\nyou must provide a second copy of the document with the portions you believe qualify for\nconfidential treatment redacted and an explanation of why you believe the redacted\ninformation qualifies for confidential treatment under 5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days\nof receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this\nNotice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged\n3\n\n\n\nin this Notice without further notice to you and to issue an Order Directing Amendment. If\nyour plans or procedures are found inadequate as alleged in this Notice, you may be ordered to\namend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are\nnot contesting this Notice, we propose that you submit your amended procedures to my office\nwithin [number of days] days of receipt of this Notice. This period may be extended by\nwritten request for good cause. Once the inadequacies identified herein have been addressed\nin your amended procedures, this enforcement action will be closed.\nIt is requested (not mandated) that Targa Resources Operating LLC, maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Allan Beshore, Director,\nCentral Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 3-2019-6005M and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\nSincerely,\nAllan C. Beshore\nDirector, Central Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\nCopy:\nMr. Clark White\nExecutive VP Engineering and Ops\nTarga Resources\n811 Louisiana St., Suite 2100\nHouston, TX 77002\n4","truncated":false,"body_characters":11528}