{"operation":"document","citation":"CPF 420205011M","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":"2020-10-06","effective_on":null,"summary":"CLOSED notice of amendment citing 195.402(a), 195.64(c)(1)(iii).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-420205011m.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-420205011m.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-420205011m","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/420205011M","body":"Notice of Amendment involving TARGA NGL PIPE LINE CO. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.64(c)(1)(iii). The case was opened on 2020-10-06 and is reported as closed as of 2020-12-17. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n420205011M_Closure Letter_12172020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205011M/420205011M_Closure%20Letter_12172020.pdf\n\n420205011M_Closure Letter_12172020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205011M/420205011M_Closure%20Letter_12172020_text.pdf\n\n420205011M_Notice of Amendment_10062020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205011M/420205011M_Notice%20of%20Amendment_10062020.pdf\n\n420205011M_Notice of Amendment_10062020_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205011M/420205011M_Notice%20of%20Amendment_10062020_text.pdf\n\n420205011M_Operator Response to Notice_11052020.pdf: https://primis.phmsa.dot.gov/enforcement-documents/420205011M/420205011M_Operator%20Response%20to%20Notice_11052020.pdf\n\n420205011M_Notice of Amendment_10062020_text.pdf\n\nNOTICE OF AMENDMENT\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nOctober 6, 2020\nClark White\nExecutive Vice President, Engineering and Operations\nTarga NGL Pipeline Company\n811 Louisiana Street, Suite 2100\nHouston Texas 77002 - 1400\nCPF 4-2020-5011M\nDear Mr. White:\nFrom July 15, 2019 through October 23, 2019, a representative of the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter\n601 of 49 United States Code (U.S.C.) inspected your Targa NGL Pipeline Company’s (Targa)\nprocedures for operations and maintenance in Houston, Texas.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nTarga’s procedures, as described below:\n1. §195.402 Procedural manual for operations, maintenance, and emergencies.\n(a) General. Each operator shall prepare and follow for each pipeline system a\nmanual of written procedures for conducting normal operations and maintenance\nactivities and handling abnormal operations and emergencies. This manual shall be\nreviewed at intervals not exceeding 15 months, but at least once each calendar year,\nand appropriate changes made as necessary to insure that the manual is effective.\nThis manual shall be prepared before initial operations of a pipeline system\ncommence, and appropriate parts shall be kept at locations where operations and\nmaintenance activities are conducted.\n\n\n\n2\nTarga NGL Pipeline Company’s (Targa) written Operation, Maintenance, and Emergency Manual\n(last revised 2/22/2019) was inadequate as it does not provide detailed written procedures for\nperforming activities on the pipeline facility. The written procedures often parrot, and in some\ninstances, are vague as to how an activity is to be performed. Procedures reviewed and found\ninadequate include:\n1. Cathodic Protection Requirements (reference §195.563) Targa Hazardous OM&E –\nCathodic Protection, last revised on 06/28/2010;\n2. Welding of Supports and Braces (reference §195.208) Targa Hazardous Liquid OM&E –\nConstruction, last revised 02/27/2013;\n3. Testing of Tie-Ins (reference §195.308) Targa Hazardous Liquid OM&E – Pressure\nTesting, last revised 12/20/2007;\n4. Test Medium (reference §195.306) Targa Hazardous Liquid OM&E – Pressure Testing,\nlast revised 12/20/2007;\n5. Testing of components (reference §195.305) Targa Hazardous Liquid OM&E – Pressure\nTesting, last revised 12/20/2007; and\n6. Pressure Testing (reference §195.304) Targa Hazardous Liquid OM&E – Pressure\nTesting, last revised 12/20/2007.\nThe procedures presented parrot the regulation and do not include a process of how to perform the\nlisted activities.\nTarga must revise its written procedures to provide guidance on how the tasks associated with the\nactivities are to be carried out for all the above-mentioned procedures.\n2. §195.64 National Registry of Pipeline and LNG Operators.\n(c) Changes. Each operator must notify PHMSA electronically through the National\nRegistry of Pipeline and LNG Operators at http://opsweb.phmsa.dot.gov, of certain\nevents.\n(1) An operator must notify PHMSA of any of the following events not later than 60\ndays before the event occurs:\n(iii) Reversal of product flow direction when the reversal is expected to last more than\n30 days. This notification is not required for pipeline systems already designed for bi-\ndirectional flow;\nTarga’s written procedure for providing notifications to the National Registry was inadequate.\nTarga Hazardous Liquid Pipeline Normal and Maintenance Procedures – National Registry of\nPipeline and LNG Operators, revised 03/05/2012, does not include a requirement for the\nnotification for the reversal of product flow direction when the reversal is expected to last more\nthan 30 days as required in §195.64(c)(iii).\nThe procedure was re-revised on 07/16/2019 during the inspection to include the requirement of\n§195.64(c)(iii) and no further amendments are required.\n\n\n\n3\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).\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 60 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 NGL Pipeline Company 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, P.E,\nDirector, Southwest Region, Pipeline and Hazardous Materials Safety Administration. In\ncorrespondence concerning this matter, please refer to CPF 4-2020-5011M and, for each\ndocument you submit, please 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\n\n420205011M_Closure Letter_12172020_text.pdf\n\nELECTRONIC MAIL - RETURN RECEIPT REQUESTED\nDecember 17, 2020\nClark White\nExecutive Vice President Engineering and Operations\nTarga NGL Pipeline Company\n811 Louisiana Street, Suite 2100\nHouston, Texas 77002 - 1400\nCPF 4-2020-5011M\nDear Mr. White:\nOn July 15, 2019 through October 23, 2019, a representative from the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code,\nconducted an on-site pipeline safety inspection of Targa NGL Pipeline Company’s (Targa)\nprocedures in Houston, Texas. As a result of the inspection, Targa was issued a Notice of\nAmendment on October 6, 2020, which proposed amendment of your procedures.\nTarga submitted its amended procedures on November 5, 2020. My staff has reviewed the\namended procedures, and it appears that the inadequacies outlined in this Notice of Amendment\nhave been corrected.\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","truncated":false,"body_characters":8782}