{"operation":"document","citation":"CPF 420185024M","title":"TARGA NGL PIPE LINE CO — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2018-11-14","effective_on":null,"summary":"CLOSED notice of amendment citing 195.446(c)(4), 195.452(e)(1), 195.452(e)(2), 195.452(j)(2).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185024m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185024m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420185024m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420185024M","body":"Notice of Amendment involving TARGA NGL PIPE LINE CO. PHMSA's enforcement data identifies the cited regulations as 195.446(c)(4),  195.452(e)(1),  195.452(e)(2),  195.452(j)(2). The case was opened on 2018-11-14 and is reported as closed as of 2020-04-30. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420185024M_Closure Letter_04302020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185024M/420185024M_Closure%20Letter_04302020.pdf\n\n420185024M_Closure Letter_04302020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185024M/420185024M_Closure%20Letter_04302020_text.pdf\n\n420185024M_Notice of Amendment_11142018.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185024M/420185024M_Notice%20of%20Amendment_11142018.pdf\n\n420185024M_Notice of Amendment_11142018_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185024M/420185024M_Notice%20of%20Amendment_11142018_text.pdf\n\n420185024M_Operator Request for Hearing and Statement of Issues_01312019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185024M/420185024M_Operator%20Request%20for%20Hearing%20and%20Statement%20of%20Issues_01312019.pdf\n\n420185024M_Operator Response to Notice and Request for Hearing_01312019.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420185024M/420185024M_Operator%20Response%20to%20Notice%20and%20Request%20for%20Hearing_01312019.pdf\n\n420185024M_Closure Letter_04302020_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nApril 30, 2020\nHunter Battle\nVice President\nTarga NGL Pipeline Company\n1000 Louisiana St. Suite 4300\nHouston, Texas 77002\nCPF 4-2018-5024M\nDear Mr. Battle:\nFrom June 13- 30, 2016, representatives of the Office of Pipeline Safety (OPS), Southwest Region,\npursuant to Chapter 601 of 49 United States Code, conducted a pipeline safety inspection of Targa\nNGL Pipeline Company (Targa), facilities and records pertaining to the Product Pipeline system\nwith pipelines in Louisiana and Texas. As a result of the inspection, Targa was issued a Notice of\nAmendment on November 14, 2018, which proposed amendment of your procedures.\nTarga submitted its amended procedures on April 30, 2019. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment 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\n420185024M_Notice of Amendment_11142018_text.pdf\n\nNOTICE OF AMENDMENT\nCERTIFIED MAIL - RETURN RECEIPT REQUESTED\nNovember 14, 2018\nMr. Hunter Battle\nVice President\nTarga NGL Pipeline Company\n1000 Louisiana St. Suite 4300\nHouston, Texas 77002\nCPF No. 4-2018-5024M\nDear Mr. Battle:\nOn June 13- 30, 2016, representatives of the Office of Pipeline Safety (OPS), Southwest Region,\npursuant to Chapter 601 of 49 United States Code, conducted a pipeline safety inspection of Targa\nNGL Pipeline (Targa), facilities and records pertaining to the Product Pipeline system with\npipelines in Louisiana and Texas.\nAs a result of the review of the Targa operations, maintenance, and emergency response manual,\nthe requirements for which are set forth in Title 49 Code of Federal Regulations, Part 195, the\nfollowing inadequate procedures are noted:\n1. § 195.446(c)(4) Control room management.\n(c) Provide adequate information. Each operator must provide its controllers with the\ninformation, tools, processes and procedures necessary for the controllers to carry out the\nroles and responsibilities the operator has defined by performing each of the following:\n(4) Test any backup SCADA systems at least once each calendar year, but at intervals not\nto exceed 15 months\n\n\n\nTarga’s process and procedure documented in the Control Room Management Plan, Hackberry\nStorage Facility, backup SCADA system, page 12, is inadequate. The process and procedure lack\nspecifics in reference as to how the transition from normal to emergency mode will take place,\nwho will be responsible for implementing the emergency mode, how the testing of the backup\nSCADA system will be performed and, how pipeline operation will be returned to the primary\nSCADA control.\nTarga must amend current process and procedures, these process and procedures should be kept\nor referenced in the Control Center Manual of operations as required by 195.446(c)(4).\n2. §195.452 Pipeline integrity management in high consequence areas\n(e) What are the risk factors for establishing an assessment schedule (for both the baseline and\ncontinual integrity assessments)? (1) An operator must establish an integrity assessment\nschedule that prioritizes pipeline segments for assessment (see paragraphs (d)(1) and (j)(3)\nof this section). An operator must base the assessment schedule on all risk factors that reflect\nthe risk conditions on the pipeline segment. The factors an operator must consider include,\nbut are not limited to:\n(i) Results of the previous integrity assessment, defect type and size that the assessment\nmethod can detect, and defect growth rate;\n(ii) Pipe size, material, manufacturing information, coating type and condition, and seam\ntype;\n(iii) Leak history, repair history and cathodic protection history;\n(iv) Product transported;\n(v) Operating stress level;\n(vi) Existing or projected activities in the area;\n(vii) Local environmental factors that could affect the pipeline (e.g., corrosivity of soil,\nsubsidence, climatic);\n(viii) geo-technical hazards; and (ix) Physical support of the segment such as by a cable\nsuspension bridge.\n(2) Appendix C of this part provides further guidance on risk factors.\nTarga’s procedure in Section 5.0 Risk Analysis, 5.2 Hazard /Threat Identification is inadequate as\nit does not allow for a technical justification for not considering a given risk factor, specifically\nthe threat of SCC to its pipeline system.\nPHMSA inspectors requested specific procedures that discussed technical justification for Targa\nnot considering the threat of SCC to its pipeline system. Targa provided PHMSA inspectors a\ncopy of the SCC criteria that is utilized to either consider or not consider SCC as a risk factor.\n\n\n\nTarga must amend current process and procedures, in Section 5.2 of the Integrity Management\nProgram for Liquid Transmission Pipelines by adding language that allows for a technical\njustification for not considering risk factors to ensure compliance with 195.452(e).\n3. §195.452 Pipeline integrity management in high consequence areas\n(j) What is a continual process of evaluation and assessment to maintain a pipeline's integrity?\n(2) Evaluation. An operator must conduct a periodic evaluation as frequently as needed to\nassure pipeline integrity. An operator must base the frequency of evaluation on risk factors\nspecific to its pipeline, including the factors specified in paragraph (e) of this section. The\nevaluation must consider the results of the baseline and periodic integrity assessments,\ninformation analysis (paragraph (g) of this section), and decisions about remediation, and\npreventive and mitigative actions (paragraphs (h) and (i) of this section).\nTarga’s procedure in Section 7.0 Continual Process of Evaluation and Assessment, 7.1 Periodic\nEvaluation, is inadequate because it does not set a specific frequency of when Periodic Evaluations\nwill be performed.\nOn July 9, 2016, Targa revised its Integrity Management program which included a revision to\nSection 7.0 Continual Process of Evaluation and Assessment, 7.1 Periodic Evaluation by adding\nlanguage that allows for Periodic Evaluations be performed annually.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.237. 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). If you do not respond within 30 days of receipt of this Notice,\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.\nIf, after opportunity for a hearing, your plans or procedures are found inadequate as alleged in this\nNotice, you may be ordered to amend your plans or procedures to correct the inadequacies (49\nC.F.R. § 190.237). If you are not contesting this Notice, we propose that you submit your amended\nprocedures to my office within 90 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 in\nyour amended procedures, this enforcement action will be closed.\n\n\n\nIt is requested (not mandated) that Targa NGL Pipelines maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to R. M. Seeley, Director, SW Region, Pipeline and\nHazardous Materials Safety Administration. In correspondence concerning this matter, please refer\nto CPF No. 4-2018-5024M and, for each document you submit, please provide a copy in electronic\nformat whenever possible.\nIn regards to Item 3 listed above, Targa NGL Pipelines provided revised procedures via email soon\nafter the inspection. This procedure submittal was reviewed and deemed adequate. No further\naction is required in response to this Notice and this case is now closed. Thank you for your\ncooperation.\nSincerely,\nMary L. McDaniel, P.E.\nDirector, Southwest Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Compliance Proceedings","truncated":false,"body_characters":10397}