{"operation":"document","citation":"CPF 420181008M","title":"TARGA RESOURCES OPERATING LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-07-03","effective_on":null,"summary":"CLOSED notice of amendment citing 192.605(b)(2), 192.612(a), 192.615(a)(1), 192.805(b).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420181008m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420181008m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420181008m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420181008M","body":"Notice of Amendment involving TARGA RESOURCES OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 192.605(b)(2),  192.612(a),  192.615(a)(1),  192.805(b). The case was opened on 2018-07-03 and is reported as closed as of 2018-09-27. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420181008M_Closure Letter_09272018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181008M/420181008M_Closure%20Letter_09272018.pdf\n\n420181008M_Closure Letter_09272018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181008M/420181008M_Closure%20Letter_09272018_text.pdf\n\n420181008M_Notice of Amendment_07032018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181008M/420181008M_Notice%20of%20Amendment_07032018.pdf\n\n420181008M_Notice of Amendment_07032018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181008M/420181008M_Notice%20of%20Amendment_07032018_text.pdf\n\n420181008M_Operator Response to Notice_07232018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420181008M/420181008M_Operator%20Response%20to%20Notice_07232018.pdf\n\n420181008M_Closure Letter_09272018_text.pdf\n\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nSeptember 27, 2018\nFrancis Foret\nSenior Vice President-Operations\nTarga Resources Operating, L.L.C\n1000 Louisiana St., Suite 2100\nHouston, TX 77002\nCPF 4-2018-1008M\nDear Mr. Foret:\nDuring the months of April 11-13, 2017 to October 12, 2017, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States\nCode (U.S.C.) inspected the Targa Resources Operating LLC (Targa), Offshore Pelican/Seahawk\nGas System in OCS-Gulf of Mexico. As a result of the inspection, Targa was issued a Notice of\nAmendment on July 3, 2018, which proposed amendment of your procedures.\nTarga submitted amended procedures on July 23, 2018. My staff has reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Admendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\n\n420181008M_Notice of Amendment_07032018_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nJuly 3, 2018\nFrancis Foret\nSenior Vice President-Operations\nTarga Resources Operating, L.L.C\n1000 Louisiana St., Suite 2100\nHouston, TX 77002\nCPF 4-2018-1008M\nDear Mr. Foret:\nDuring the months of April 11-13, 2017 to October 12, 2017, a representative of the Pipeline and\nHazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States\nCode (U.S.C.) inspected the Targa Resources Operating LLC (Targa), Offshore Pelican/Seahawk\nGas System in OCS-Gulf of Mexico.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTarga Resources Operating plans or procedures, as described below:\n1. §192.605 Procedural manual for operations, maintenance, and emergencies.\n(b) Maintenance and normal operations. The manual required by paragraph (a) of\nthis section must include procedures for the following, if applicable, to provide safety\nduring maintenance and operations.\n(2) Controlling corrosion in accordance with the operations and maintenance\nrequirements of subpart I of this part.\n\n\n\nTarga’s Corrosion Control Procedures does not meet §192.605(c) in that there is no reference to\nthe form designated as the \"Offshore Corrosion Inspection Report\". Targa employees have been\nusing this form for the past four (4) years to conduct and document Atmospheric Corrosion Control\nInspections. However, no reference to this form can be found in the procedures. This form is not\nincluded on the page that list forms within the Targa Corrosion Control Procedures. According to\nthe operator, the procedure does not have to have a specific form to conduct the Atmospheric\nCorrosion Control inspection, the inspection just has to be documented. If the form is not used\nthen how does Targa ensure that personnel are following procedures, trained properly and\ncapturing all information that is required by the corrosion procedure.\nTarga must revise the Corrosion Control procedures to include the form “Offshore Corrosion\nInspection Report” as part of those procedures.\n2. §192.615 Emergency plans.\n(a) Each operator shall establish written procedures to minimize the hazard resulting\nfrom a gas pipeline emergency. At a minimum, the procedures must provide for the\nfollowing:\n(1) Receiving, identifying, and classifying notices of events which require immediate\nresponse by the operator.\nTarga’s Emergency response procedure does not include instructions for individuals who normally\nreceive calls for the operator, who identifies the situation, directs callers to seek safety first, and\nthen gathers critical information to promptly initiate the operator's response efforts. The Targa\nMidstream Services LLC, Gulf of Mexico; Regional Oil Spill Response Plan is incorporated in the\nEmergency Plan and some of the procedures that are outlined in the Regional Oil Spill Response\nPlan are referenced and used to comply with §192.615. During a discussion with Targa personnel,\nit was noted that the initial call from the person notifying Targa is not documented by the Targa\nemployee receiving the call. The procedure needs to be revised so that the Targa employee\ndocuments that initial notification. This record would indicate when Targa was first notified of any\nleaks, incidents or emergencies and what initial emergency response was performed.\nTarga must revise its procedures to include that the initial notification of leaks, incidents or\nemergencies are documented by Targa employees.\n3. §192.612 Underwater inspection and reburial of pipelines in the Gulf of Mexico\nand its inlets.\n(a) Each operator shall prepare and follow a procedure to identify its pipelines in the\nGulf of Mexico and its inlets in waters less than 15 feet (4.6 meters) deep as measured\nfrom mean low water that are at risk of being an exposed underwater pipeline or a\nhazard to navigation. The procedures must be in effect August 10, 2005.\n2\n\n\n\nTarga’s Periodic Underwater Inspection Procedures (rev. 9/24/2013) does not comply with the\nrecordkeeping requirements of §192.709(c). Page 8 of 17 of the procedure is designated as\nRecord Retention. This section states the inspection will be \"kept for at least two years, or until\nthe next inspection or test is performed, whichever is longer\". The requirement in §192.709(c)\nstates that records of each patrols, surveys, inspections.....must be retained for at least five (5)\nyears.\nTarga must revise the Periodic Underwater Inspection Procedures to state that the record of the\nsurvey will be retained for five (5) years as required by §192.709(c).\n4. §192.805 Qualification program.\nEach operator shall have and follow a written qualification program. The program\nShall include provisions to:\n(b) Ensure through evaluation that individuals performing covered tasks are\nqualified;\nTarga’s Operator Qualification program does not comply with the recordkeeping requirements of\n§192.807 (b). During the inspection, PHMSA reviewed the covered task qualification Evaluation\nMethod for Valve Maintenance (OQ – M-08-LC). It was noted that the following statement was\nlisted on the evaluation form: \"Records will be kept for a minimum of two years or until the new\ninspection is performed, whichever is greater.”\nThe Targa Qualification Evaluation Method for Valve Maintenance needs to be revised to reflect\nthe correct retention time period of five (5) years as required by §192.807(b).\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Compliance\nProceedings. Please refer to this document and note the response options. Be advised that all\nmaterial you submit in response to this enforcement action is subject to being made publicly\navailable. If you believe that any portion of your responsive material qualifies for confidential\ntreatment under 5 U.S.C. 552(b), along with the complete original document you must provide a\nsecond copy of the document with the portions you believe qualify for confidential treatment\nredacted and an explanation of why you believe the redacted information qualifies for confidential\ntreatment under 5 U.S.C. 552(b).\n3\n\n\n\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 of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Targa Resources Operating maintain documentation of the\nsafety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel, Director,\nSouthwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence\nconcerning this matter, please refer to CPF 4-2018-1008M and, for each document you submit,\nplease provide a copy in electronic format whenever possible.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings\n4","truncated":false,"body_characters":10292}