{"operation":"document","citation":"CPF 420135001","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":"2013-01-02","effective_on":null,"summary":"CLOSED notice of probable violation citing 195.403(b), 195.403(c), 195.575(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135001.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135001.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420135001","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420135001","body":"Notice of Probable Violation involving TARGA RESOURCES OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 195.403(b),  195.403(c),  195.575(c). The case was opened on 2013-01-02 and is reported as closed as of 2013-08-14. Proposed civil penalty: $34,000. Assessed civil penalty: $34,000. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420135001_Closure Letter_08142013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135001/420135001_Closure%20Letter_08142013.pdf\n\n420135001_Closure Letter_08142013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135001/420135001_Closure%20Letter_08142013_text.pdf\n\n420135001_Final Order_05292013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135001/420135001_Final%20Order_05292013.pdf\n\n420135001_Final Order_05292013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135001/420135001_Final%20Order_05292013_text.pdf\n\n420135001_NOPV PCP PCO_01022013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135001/420135001_NOPV%20PCP%20PCO_01022013.pdf\n\n420135001_NOPV PCP PCO_01022013_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135001/420135001_NOPV%20PCP%20PCO_01022013_text.pdf\n\n420135001_Operator Response to Notice_01292013.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420135001/420135001_Operator%20Response%20to%20Notice_01292013.pdf\n\n420135001_Closure Letter_08142013_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nAugust 14, 2013\nMr. Hunter Battle\nVice President, TX/LA Gulf Coast\nTarga Resources Operating LP\n1000 Louisiana, Suite 4300\nHouston, TX 77002\nCPF 4-2013-5001\nDear Mr. Battle:\nOn January 2, 2013, the Pipeline and Hazardous Materials Safety Administration issued to Targa\nResources Operating, LP (Targa), a Notice of Probable Violation, Proposed Civil Penalty and\nProposed Compliance Order. Based on our review of the documentation you provided, it has\nbeen determined that you have complied with the terms of this Notice.\nAccordingly, this case is now closed and no further action is contemplated with respect to the\nmatters involved in this case. Thank you for your cooperation in this matter.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n\n420135001_Final Order_05292013_text.pdf\n\nMAY 29, 2013\nMr. Joe Bob Perkins, CEO\nTarga Resources Operating, LP\nTarga Resources Corporation\n1000 Louisiana, Suite 4300\nHouston, Texas 77002\nRe: CPF No. 4-2013-5001\nDear Mr. Perkins:\nEnclosed please find the Final Order issued in the above-referenced case. It makes findings of\nviolation, assesses a civil penalty of $34,000, and specifies actions that need to be taken by Targa\nResources Operating, LP, to comply with the pipeline safety regulations. This is to acknowledge\nreceipt of a partial payment, by wire transfer dated February 2, 2013, in the amount of $14,100.\nThe remaining penalty payment terms are set forth in the Final Order. When the civil penalty\nhas been paid in full and the terms of the compliance order completed, as determined by the\nDirector, Southwest Region, this enforcement action will be closed. Service of the Final Order\nby certified mail is deemed effective upon the date of mailing, or as otherwise provided under 49\nC.F.R. § 190.5.\nThank you for your cooperation in this matter.\nSincerely,\nJeffrey D. Wiese\nAssociate Administrator\nfor Pipeline Safety\nEnclosure\ncc: Mr. Rodrick M. Seeley, Director, Southwest Region, OPS\nMr. Alan Mayberry, Deputy Associate Administrator for Field Operations, OPS\nMs. Elizabeth Hawkins, Esquire, Senior Regulatory Counsel, Targa Resources\nCorporation\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\n\n\n\nU.S. DEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nWASHINGTON, D.C. 20590\n____________________________________\n)\nIn the Matter of )\n)\nTarga Resources Operating, LP, ) CPF No. 4-2013-5001\n)\nRespondent. )\n____________________________________)\nFINAL ORDER\nBetween June and September 2012, pursuant to 49 U.S.C. § 60117, a representative of the\nPipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), conducted an on-site pipeline safety inspection of the facilities and records of Targa\nResources Operating, LP (Targa or Respondent), in Sulphur, Louisiana. Targa is a subsidiary of\nTarga Resources Corporation, which owns and operates over 10,000 miles of natural gas\ngathering and NGL pipelines, 22 gas processing plants, and 13 storage terminals in Louisiana,\nKentucky, Texas, Mississippi, Florida, New Jersey, Tennessee, Washington, Maryland and the\nGulf of Mexico.1\nAs a result of the inspection, the Director, Southwest Region, OPS (Director), issued to\nRespondent, by letter dated January 2, 2013, a Notice of Probable Violation, Proposed Civil\nPenalty, and Proposed Compliance Order (Notice). In accordance with 49 C.F.R. § 190.207, the\nNotice proposed finding that Targa had violated 49 C.F.R. §§ 195.403 and 195.575 and proposed\nassessing a civil penalty of $34,000 for the alleged violations. The Notice also proposed\nordering Respondent to take certain measures to correct one of the alleged violations.\nTarga responded to the Notice by letter dated January 29, 2013 (Response). The company\ncontested the allegations contained in Item 1 and offered additional information in response to\nthe Notice. Targa did not contest the allegations contained in Item 2, and paid the proposed\npenalty for this item, in the amount of $14,100.\nRespondent did not request a hearing and therefore has waived its right to one.\nFINDINGS OF VIOLATION\nThe Notice alleged that Respondent violated 49 C.F.R. Part 195 as follows:\n1 Pipeline Safety Violation Report (Violation Report), (May 10, 2011) (on file with PHMSA), at 1.\n\n\n\n2\nItem 1: The Notice alleged that Respondent violated 49 C.F.R. § 195.403, which states, in\nrelevant part:\n§ 195.403 Emergency response training.\n(a) …\n(b) At the intervals not exceeding 15 months, but at least once\neach calendar year, each operator shall:\n(1) Review with personnel their performance in meeting the\nobjectives of the emergency response training program set forth in\nparagraph (a) of this section; and\n(2) Make appropriate changes to the emergency response training\nprogram as necessary to ensure that it is effective.\n(c) Each operator shall require and verify that its supervisors\nmaintain a thorough knowledge of that portion of the emergency\nresponse procedures established under 195.402 for which they are\nresponsible to ensure compliance.\nThe Notice alleged that Respondent violated two provisions of 49 C.F.R. § 195.403. First, it\nalleged that Targa violated § 195.403(b) by failing to review with personnel their performance in\nmeeting the objectives of the company’s emergency response program per the requirements of\n§ 195.403. Specifically, the Notice alleged that the last review of the program was conducted in\nFebruary and June of 2010, but that it had not been done again during the 15 months prior to the\nPHMSA inspection.\nSecond, the Notice alleged that Respondent violated § 195.403(c) by failing, in 2011, to require\nand verify that its supervisors maintained a thorough knowledge of the company’s emergency\nresponse procedures for which they were responsible.\nIn its Response, Targa asserted that it did not use a “review of the emergency response program”\nto fulfill the requirements of § 195.403(b). Instead, the company used its “Annual Personnel\nPerformance Reviews” to satisfy the regulation. Additionally, Targa contended that such\n“Annual Personnel Performance Reviews” also satisfied the requirements of § 195.403(c) by\nestablishing a means of requiring and verifying that its supervisors maintained a thorough\nknowledge of the company’s emergency response procedures. In support of its position, Targa\nprovided four examples of its employee performance reviews.\nUpon reviewing the record and considering Targa’s argument, I find that Respondent violated\nboth 49 C.F.R. § 195.403(b) and (c) by failing to review the performance of its employees as\nspecifically related to the company’s emergency response training program and by failing to\nensure that its supervisors maintained a thorough knowledge of that portion of Targa’s\nemergency response program for which they were responsible. The documents provided by\nTarga only give general information about each employee and the skills he or she has in\nperforming his or her job. Specifically, under #3, “Job Knowledge,” the only provision in the\nperformance review forms that could be considered evidence of its compliance with § 195.403(b)\nand (c) contains no information about the employee’s emergency response training or the\nemployee’s knowledge of emergency procedures. It merely discusses the employee’s\n\n\n\n3\n“understanding of essential functions, and duties within the scope of the position.” This generic\ndescription does not amount to documentation or evidence confirming that the employee’s\nperformance met the objectives of the company’s emergency response training program under\n§ 195.403(b) or (c).\nAccordingly, I find that the documents supplied by Targa fail to establish the company’s\ncompliance with § 195.403. When coupled with the undisputed allegation that a Targa employee\nhad acknowledged to the PHMSA inspector that the company’s Emergency Response training\nhad been inadvertently removed from the company’s block training program due to an\nadministrative oversight in 2011, I am convinced that Respondent violated\n49 C.F.R. § 195.403(b) and (c).\nItem 2: The Notice alleged that Respondent violated 49 C.F.R. § 195.575(c), which states:\n§ 195.575 Which facilities must I electrically isolate and what inspections,\ntests, and safeguards are required?\n(a) . . .\n(c) You must inspect and electrically test each electrical isolation to\nassure the isolation is adequate.\nThe Notice alleged that Respondent violated 49 C.F.R. § 195.575(c) by failing to inspect and\nelectronically test three electrical insolation devices since the date they were first installed.\nSpecifically, the Notice alleged that Targa, in violation of its own procedure, Targa Liquid\nPipeline Corrosion Procedures for Electrical Isolation, failed to inspect three insulating devices\ninstalled on what is referred to as the “Orange Extension Pipeline” since they were installed.\nRespondent did not contest this allegation of violation. Accordingly, based upon a review of all\nof the evidence, I find that Respondent violated 49 C.F.R. § 195.575(c) by failing to properly\ninspect three electrical insolation devices installed on the Orange Extension Pipeline.\nThese findings of violation will be considered prior offenses in any subsequent enforcement\naction taken against Respondent.\nASSESSMENT OF PENALTY\nUnder 49 U.S.C. § 60122, Respondent is subject to an administrative civil penalty not to exceed\n$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any\nrelated series of violations.2 In determining the amount of a civil penalty under\n49 U.S.C. § 60122 and 49 C.F.R. § 190.225, I must consider the following criteria: the nature,\ncircumstances, and gravity of the violation, including adverse impact on the environment; the\ndegree of Respondent’s culpability; the history of Respondent’s prior offenses; and any effect\n2 The Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011, Pub. L. No. 112-90, § 2(a)(1), 125 Stat.\n1904, effective January 3, 2012, increased the civil penalty liability for violating a pipeline safety standard to\n$200,000 per violation for each day of the violation, up to a maximum of $2,000,000 for any related series of\nviolations.\n\n\n\n4\nthat the penalty may have on its ability to continue doing business; and the good faith of\nRespondent in attempting to comply with the pipeline safety regulations. In addition, I may\nconsider the economic benefit gained from the violation without any reduction because of\nsubsequent damages, and such other matters as justice may require. The Notice proposed a total\ncivil penalty of $34,000 for the violations cited above.\nItem 1: The Notice proposed a civil penalty of $19,900 for Respondent’s violation of\n49 C.F.R. § 195.403(b) and (c), for failing to review with company personnel their performance\nin meeting the objectives of the company’s emergency response training program. Additionally,\nit alleged that the company failed to ensure that its supervisors maintained a thorough knowledge\nof Targa’s emergency response procedures. As previously noted, I found that Targa’s employee\nperformance reviews did not serve to satisfy the requirements in § 195.403(b) and (c) that the\ncompany evaluate each employee’s performance in meeting the specific safety objectives\noutlined in paragraph (a) of that regulation. By failing to include emergency response as a\nspecific element in its performance review process, Respondent was unable to verify and\ndocument that its employees were adequately trained to deal with pipeline emergencies.\nAccordingly, having reviewed the record and considered the assessment criteria, I assess\nRespondent a civil penalty of $19,900 for violation of 49 C.F.R. § 195.403.\nItem 2: The Notice proposed a civil penalty of $14,100 for Respondent’s violation of\n49 C.F.R. § 195.575(c), for failing to properly and timely inspect three insulating devices\ninstalled on the Orange Extension Pipeline. Targa paid the proposed penalty, which serves to\nclose this Item with prejudice and authorizes PHMSA to make a finding of violation.\nAccordingly, having reviewed the record and considered the assessment criteria, I assess\nRespondent a civil penalty of $14,100 for violation of 49 C.F.R. § 195.575(c).\nIn summary, having reviewed the record and considered the assessment criteria for each of the\nItems cited above, I assess Respondent a total civil penalty of $34,000.\nPayment of the civil penalty must be made within 20 days of service. Federal regulations\n(49 C.F.R. § 89.21(b)(3)) require such payment to be made by wire transfer through the Federal\nReserve Communications System (Fedwire), to the account of the U.S. Treasury. Detailed\ninstructions are contained in the enclosure. Questions concerning wire transfers should be\ndirected to: Financial Operations Division (AMZ-341), Federal Aviation Administration, Mike\nMonroney Aeronautical Center, P.O. Box 269039, Oklahoma City, Oklahoma 73125. The\nFinancial Operations Division telephone number is (405) 954-8893.\nFailure to pay the $34,000 civil penalty in full will result in accrual of interest at the current\nannual rate in accordance with 31 U.S.C. § 3717, 31 C.F.R. § 901.9 and 49 C.F.R. § 89.23.\nPursuant to those same authorities, a late penalty charge of six percent (6%) per annum will be\ncharged if payment is not made within 110 days of service. Furthermore, failure to pay the civil\npenalty may result in referral of the matter to the Attorney General for appropriate action in a\ndistrict court of the United States.\n\n\n\n5\nCOMPLIANCE ORDER\nThe Notice proposed a compliance order with respect to Items 1 and 2 in the Notice for\nviolations of 49 C.F.R. §§ 195.403 and 195.575, respectively. Under 49 U.S.C. § 60118(a), each\nperson who engages in the transportation of hazardous liquids or who owns or operates a\npipeline facility is required to comply with the applicable safety standards established under\nchapter 601. Pursuant to the authority of 49 U.S.C. § 60118(b) and 49 C.F.R. § 190.217,\nRespondent is ordered to take the following actions to ensure compliance with the pipeline safety\nregulations applicable to its operations:\n1. With respect to the violation of § 195.403 (Item 1), Respondent must review its\nemergency response program with company personnel, including controllers at the\nHackBerry Storage Facility, and, if necessary, make appropriate changes to the\ncompany’s emergency response training program to ensure its effectiveness. In\naddition, Targa must verify that its supervisors maintain a thorough knowledge of that\nportion of the emergency response procedures for which they are responsible to\nensure compliance.\n2. Respondent must complete and submit all documentation listed in Paragraph 1 of\nthis Proposed Compliance Order within forty-five (45) days after receipt of the Final\nOrder.\n3. It is requested (not mandated) that Respondent maintain documentation of the\nsafety improvement costs associated with fulfilling this Compliance Order and submit\nthe total to Rodrick Seeley, Director, Southwest Region, Pipeline and Hazardous\nMaterials Safety Administration. It is requested that these costs be reported in two\ncategories: 1) total cost associated with preparation/revision of plans, procedures,\nstudies and analyses; and 2) total cost associated with replacements, additions and\nother changes to pipeline infrastructure.\nThe Director may grant an extension of time to comply with any of the required items upon a\nwritten request timely submitted by the Respondent and demonstrating good cause for an\nextension.\nFailure to comply with this Order may result in the administrative assessment of civil penalties\nnot to exceed $100,000 for each violation for each day the violation continues or in referral to the\nAttorney General for appropriate relief in a district court of the United States.\n\n\n\n6\nUnder 49 C.F.R. § 190.215, Respondent has a right to submit a Petition for Reconsideration of\nthis Final Order. The petition must be sent to: Associate Administrator, Office of Pipeline\nSafety, PHMSA, 1200 New Jersey Avenue, SE, East Building, 2nd Floor, Washington, DC\n20590, with a copy sent to the Office of Chief Counsel, PHMSA, at the same address. PHMSA\nwill accept petitions received no later than 20 days after receipt of service of this Final Order by\nthe Respondent, provided they contain a brief statement of the issue(s) and meet all other\nrequirements of 49 C.F.R. § 190.215. The filing of a petition automatically stays the payment of\nany civil penalty assessed. Unless the Associate Administrator, upon request, grants a stay, all\nother terms and conditions of this Final Order are effective upon service in accordance with\n49 C.F.R. § 190.5.\n___________________________________ __________________________\nJeffrey D. Wiese Date Issued\nAssociate Administrator\nfor Pipeline Safety\n\n420135001_NOPV PCP PCO_01022013_text.pdf\n\nNOTICE OF PROBABLE VIOLATION\nPROPOSED CIVIL PENALTY\nand\nPROPOSED COMPLIANCE ORDER\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJanuary 2, 2013\nMr. Hunter Battle\nVice President, TX/LA Gulf Coast\nTarga Resources Operating LP\n1000 Louisiana, Suite 4300\nHouston, TX 77002\nCPF 4-2013-5001\nDear Mr. Battle:\nDuring the months of June, July, and September of 2012, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant\nto Chapter 601 of 49 United States Code inspected your Orange Extension Pipeline and\nHackberry Storage Facility in Sulphur, LA.\nAs a result of the inspection, it appears that you have committed probable violations of the\nPipeline Safety Regulations, Title 49, Code of Federal Regulations. The items inspected and the\nprobable violations are:\n1. §195.403 Emergency Response Training\n(b) At the intervals not exceeding 15 months, but at least once each calendar year, each\noperator shall:\n(1) Review with personnel their performance in meeting the objectives of the emergency\nresponse training program set forth in paragraph (a) of this section; and\n\n\n\n(2) Make appropriate changes to the emergency response training program as necessary to\nensure that it is effective.\n(c) Each operator shall require and verify that its supervisors maintain a thorough\nknowledge of that portion of the emergency response procedures established under\n§195.402 for which they are responsible to ensure compliance.\nAt the time of the inspection, Targa Resources Operating LP (Targa) failed to provide records\nindicating the company reviewed the emergency response program with Targa personnel as per\nthe requirements of 195.403 (b) (1). The last review was performed during February and June of\n2010. In addition, Targa failed to provide records indicating the company reviewed the\nemergency response program with Controllers at Hackberry Storage Facility.\nTarga, also failed to require and verify that its supervisors maintain a thorough knowledge of\nemergency response procedures as per section 403 (c) in the calendar year of 2011. The last\ndocumentation for supervisory training was dated as 6/2/2010 for Emergency Response and\n9/9/2009 for Incident Command.\nTarga Hazardous Liquids Normal Operations and Maintenance Procedures, Emergency\nResponse Training, revised on 4/8/2011 states:\n“At intervals not exceeding 15 months, but at least once each calendar year, the Area\nManager or his designee will:\n1) Review with personnel their performance in meeting the objectives of the emergency\nprogram set forth above; and\n2) Make appropriate changes to the training program as necessary to ensure that it is\neffective.\n3) Require and verify that supervisors maintain a thorough knowledge of that portion of\nthe procedures for they are responsible.”\nAnd,\nTarga Hazardous Liquids Operations, Maintenance & Emergencies Manual – Emergency\nProtection Plan, Section IV-O – Training and Review states “The Area Manager or his\ndesignee shall keep on file at the attendance and items covered at each training session”.\nAccording to the Targa representative during the inspection, the Emergency Response training\nwas removed from the block training program due to administrative oversight in 2011.\n2. §195.575 Which facilities must I electrically isolate and what inspections, tests, and\nsafeguards are required?\n2\n\n\n\n(c) You must inspect and electrically test each electrical isolation to assure the isolation is\nadequate\nTarga Liquid Pipeline Corrosion Control Procedures for Electrical Isolation, revised on\n6/24/2009 state “The effectiveness of insulation flanges or other devices will be checked upon\ninstallation and at intervals not to exceed 15 months but at least once each calendar year.” It\nfurther states, “These readings shall be included in the annual cathodic protection survey report.”\nWhile reviewing the calendar years 2009, 2010, and 2011 records associated with cathodic\nprotection, the PHMSA inspector found that Targa failed to inspect three insulating devices\ninstalled on Orange Extension pipeline since they were installed. Targa conducted an inspection\non these three insulation flanges during the month of August, 2012, after PHMSA inspector\nbrought this issue to the company attention.\nProposed Civil Penalty\nUnder 49 United States Code, § 60122, you are subject to a civil penalty not to exceed $200,000\nper violation per day the violation persists up to a maximum of $2,000,000 for a related series of\nviolations. For violations occurring prior to January 3, 2012, the maximum penalty may not\nexceed $100,000 per violation per day, with a maximum penalty not to exceed $1,000,000 for a\nrelated series of violations. The Compliance Officer has reviewed the circumstances and\nsupporting documentation involved in the above probable violation(s) and has recommended that\nyou be preliminarily assessed a civil penalty of $34,000 as follows:\nItem number PENALTY\n1 $19,900\n2 $14,100\nProposed Compliance Order\nWith respect to item 1 pursuant to 49 United States Code § 60118, the Pipeline and Hazardous\nMaterials Safety Administration proposes to issue a Compliance Order to Targa Resources\nOperating LP. Please refer to the Proposed Compliance Order, which is enclosed and made a\npart of this Notice.\nResponse to this Notice\nEnclosed as part of this Notice is a document entitled Response Options for Pipeline Operators\nin Compliance Proceedings. Please refer to this document and note the response options. All\nmaterial you submit in response to this enforcement action may be made publicly available. If\nyou believe that any portion of your responsive material qualifies for confidential treatment\nunder 5 U.S.C. 552(b), along with the complete original document you must provide a second\ncopy of the document with the portions you believe qualify for confidential treatment redacted\nand an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b). If you do not respond within 30 days of receipt of this Notice,3\n\n\n\nthis constitutes a waiver of your right to contest the allegations in this Notice and authorizes the\nAssociate Administrator for Pipeline Safety to find facts as alleged in this Notice without further\nnotice to you and to issue a Final Order.\nIn your correspondence on this matter, please refer to CPF 4-2013-5001 and for each document\nyou submit, please provide a copy in electronic format whenever possible.\nSincerely,\nR. M. Seeley\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosures: Proposed Compliance Order\nResponse Options for Pipeline Operators in Compliance Proceedings\n4\n\n\n\nPROPOSED COMPLIANCE ORDER\nPursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) proposes to issue to Targa Resources Operating LP a Compliance\nOrder incorporating the following remedial requirements to ensure the compliance of Targa with\nthe pipeline safety regulations:\n1. 2. 3. In regard to Item Number 1 of the Notice pertaining to failure to review\nemergency program, Targa must review emergency program with company\npersonnel including controllers at Hackberry Storage Facility and if necessary,\nmake appropriate changes to their emergency response training to ensure it is\neffective. In addition, Targa must verify that its supervisors maintain a thorough\nknowledge of that portion of the emergency response procedures. This must be\ndocumented.\nWithin forty-five (45) days after receipt of the Final Order related to this case,\nTarga must complete and submit all documentation listed in 1 of this Proposed\nCompliance Order.\nIt is requested (not mandated) that Targa maintain documentation of the safety\nimprovement costs associated with fulfilling this Compliance Order and submit\nthe total to R. M. Seeley, Director, Southwest Region, Pipeline and Hazardous\nMaterials Safety Administration. It is requested that these costs be reported in\ntwo categories: 1) total cost associated with preparation/revision of plans,\nprocedures, studies and analyses, and 2) total cost associated with replacements,\nadditions and other changes to pipeline infrastructure.\n5","truncated":false,"body_characters":26622}