TARGA RESOURCES OPERATING LLC — Notice of Amendment

420195006M_Notice of Amendment_02222019.pdf, page 1Official PDFU.S. Department of Transportation Houston, TX 77074 8701 S. Gessner, Suite 630 Pipeline and Hazardous Materials Safety Administration NOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED February 22, 2019 Hunter Battle Vice President, TX/LA Gulf Coast Targa Resources Operating LLC 1000 Louisiana St., Suite 4300 Houston, Texas 77002 CPF 4-2019-5006M Dear Mr. Battle: On October 10 through October 13, 2017, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Targa Resources Operating LL's procedures for control room management in Sulphur, Louisiana. On the basis of the inspection, PHMSA has identified an apparent inadequacy found within Targa's plans or procedures, as described below: §195.446 Control room management. (d) Fatigue mitigation. Each operator must implement the following methods to reduce the risk associated with controller fatigue that could inhibit a controller's ability to carry out the roles and responsibilities the operator has defined: (4) Establish a maximum limit on controller hours-of-service, which may provide for an emergency deviation from the maximum limit if necessary for the safe operation of a pipeline facility.#

420195006M_Notice of Amendment_02222019.pdf, page 2Targa's procedure titled Control Room Management Plan, Hackberry Storage Facility (CRM Plan) is inadequate as it does not meet PHMSA guidelines of appropriate methods to reduce risk associated with controller fatigue. Targa's procedures are outlined in the CRM Plan under the section titled "Maximum Hours of Service, Shift Lengths, and Rotations" which includes the following clauses: • Following are the maximum hours of service for 12-hour shifts. 1. 13 hours in any 24-hour period, including handover time. 2. Six 12-hour shifts per 7-day period The guidelines in the Control Room Management Frequently Asked Questions (CRM FAQ) section D.07. limit each controller to 65 hours of on duty time in each 7-day period. This procedure allows controllers to reach up to 78 hours through six 24-hour shifts. • Off Duty Time: 1. At least 35 hours of continuous hours spent off duty between night and day shift. This limitation does not include all situations where 35 off-duty hours are required by the CRM FAQ. Controllers should also receive 35 off-duty hours after 7 consecutive on-duty days, or after reaching 65 duty hours in a 7-day period. • An occasional holdover shift is allowed within the following parameters 1. Exceeding 13 hours in a day for no more than 2 consecutive days. Control Room supervisor shall be notified if hold over will cause shift to exceed 14 hours. 2. One 18-hour shift (19 with handover) in any 5-day period. This procedure allows controllers to exceed the limit of two 14-hour shifts in any 5-day period as prescribed by the CRM FAQ. Additionally, the CRM plan does not note the holdover shifts should not permit the controller to breach the 65-hour on-duty limit or the 35-hour off-duty requirement. Operators are permitted to deviate from the parameters outlined in the CRM FAQ given that they demonstrate why the variations do not elevate the risk of fatigue, and demonstrate that adequate fatigue risk countermeasures have been deployed. In lieu of amending the procedures, Targa may instead prove that the variations do not elevate the risk of fatigue and that adequate sure have bees do played countermeasures have been deployed. On February 28, 2018 Targa submitted to PHMSA a revised version of the CRM Plan. PHMSA determined that the revised procedure adequately addressed the changes noted in this letter. At this time, no further action is necessary and this case is now closed. 2#

420195006M_Notice of Amendment_02222019.pdf, page 3Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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 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, revised procedures, or a request for a hearing under §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 an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Targa Resources Operating LLC maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel, P.E. Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2019-5006M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Mary McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 3#

420195006M_Notice of Amendment_02222019­_text.pdf, page 1Official PDFNOTICE OF AMENDMENT CERTIFIED MAIL - RETURN RECEIPT REQUESTED February 22, 2019 Hunter Battle Vice President, TX/LA Gulf Coast Targa Resources Operating LLC 1000 Louisiana St., Suite 4300 Houston, Texas 77002 CPF 4-2019-5006M Dear Mr. Battle: On October 10 through October 13, 2017, representatives of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code inspected Targa Resources Operating LLC’s procedures for control room management in Sulphur, Louisiana. On the basis of the inspection, PHMSA has identified an apparent inadequacy found within Targa’s plans or procedures, as described below: 1. §195.446 Control room management. (d) Fatigue mitigation. Each operator must implement the following methods to reduce the risk associated with controller fatigue that could inhibit a controller's ability to carry out the roles and responsibilities the operator has defined: (4) Establish a maximum limit on controller hours-of-service, which may provide for an emergency deviation from the maximum limit if necessary for the safe operation of a pipeline facility.#

420195006M_Notice of Amendment_02222019­_text.pdf, page 2Targa’s procedure titled Control Room Management Plan, Hackberry Storage Facility (CRM Plan) is inadequate as it does not meet PHMSA guidelines of appropriate methods to reduce risk associated with controller fatigue. Targa’s procedures are outlined in the CRM Plan under the section titled “Maximum Hours of Service, Shift Lengths, and Rotations” which includes the following clauses:  Following are the maximum hours of service for 12-hour shifts. 1. 2. 13 hours in any 24-hour period, including handover time. Six 12-hour shifts per 7-day period The guidelines in the Control Room Management Frequently Asked Questions (CRM FAQ) section D.07 limit each controller to 65 hours of on duty time in each 7-day period. This procedure allows controllers to reach up to 78 hours through six 24-hour shifts.  Off Duty Time: 1. At least 35 hours of continuous hours spent off duty between night and day shift. This limitation does not include all situations where 35 off-duty hours are required by the CRM FAQ. Controllers should also receive 35 off-duty hours after 7 consecutive on-duty days, or after reaching 65 duty hours in a 7-day period.  An occasional holdover shift is allowed within the following parameters 1. Exceeding 13 hours in a day for no more than 2 consecutive days. Control Room supervisor shall be notified if hold over will cause shift to exceed 14 hours. 2. One 18-hour shift (19 with handover) in any 5-day period. This procedure allows controllers to exceed the limit of two 14-hour shifts in any 5-day period as prescribed by the CRM FAQ. Additionally, the CRM plan does not note the holdover shifts should not permit the controller to breach the 65-hour on-duty limit or the 35-hour off-duty requirement. Operators are permitted to deviate from the parameters outlined in the CRM FAQ given that they demonstrate why the variations do not elevate the risk of fatigue, and demonstrate that adequate fatigue risk countermeasures have been deployed. In lieu of amending the procedures, Targa may instead prove that the variations do not elevate the risk of fatigue and that adequate countermeasures have been deployed. On February 28, 2018 Targa submitted to PHMSA a revised version of the CRM Plan. PHMSA determined that the revised procedure adequately addressed the changes noted in this letter. At this time, no further action is necessary and this case is now closed. 2#

420195006M_Notice of Amendment_02222019­_text.pdf, page 3Response to this Notice This Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. 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 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, revised procedures, or a request for a hearing under §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 an Order Directing Amendment. If your plans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans or procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 30 days of receipt of this Notice. This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed in your amended procedures, this enforcement action will be closed. It is requested (not mandated) that Targa Resources Operating LLC maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Mary L. McDaniel, P.E. Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4-2019-5006M and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Mary L. McDaniel, P.E. Director, Southwest Region Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Compliance Proceedings 3#