TARGA DOWNSTREAM LLC — Notice of Amendment

party submissionOfficial PDF42023043NOA_Operator Response to Notice_06022023_(22-234487).pdf#

42023043NOA_Notice of Amendment_05042023_(22-234487)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT VIA ELECTRONIC MAIL May 4, 2023 G. Clark White Executive Vice President Operations Targa Downstream LLC 811 Louisiana Street Suite 2100 Houston TX 77002 CPF 4-2023-043-NOA Dear Mr. White: From February 22 to October 17, 2022, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Targa Downstream Resources, LLC’s (Targa) integrity management plan and maintenance and operations procedures in Houston, Texas. On the basis of the inspection, PHMSA has identified the apparent inadequacy found within Targa’s integrity management plan as described below: 1. § 195.402 Procedural manual for operations, maintenance, and emergencies. (a) . . . . (c) Maintenance and normal operations. The manual required by paragraph (a) of this section must include procedures for the following to provide safety during maintenance and normal operations: (1) . . . . (3) Operating, maintaining, and repairing the pipeline system in accordance with each of the requirements of this subpart and subpart H of this part. § 195.452 Pipeline integrity management in high consequence areas. (a) . . . . (h) What actions must an operator take to address integrity issues? -#

42023043NOA_Notice of Amendment_05042023_(22-234487)_text.pdf, page 2(1) . . . . (2) Discovery of condition. Discovery of a condition occurs when an operator has adequate information to determine that a condition presenting a potential threat to the integrity of the pipeline exists. An operator must promptly, but no later than 180 days after an assessment, obtain sufficient information about a condition to make that determination, unless the operator can demonstrate the 180-day interval is impracticable. If the operator believes that 180 days are impracticable to make a determination about a condition found during an assessment, the pipeline operator must notify PHMSA in accordance with paragraph (m) of this section and provide an expected date when adequate information will become available. Targa’s integrity management plan was inadequate to assure safe operation of a pipeline facility in accordance with § 195.402(c)(3). Specifically, Targa’s Integrity Management Program for Liquids Transmission Pipeline (Rev: 4/1/2020) (IMP) failed to describe what adequate information is needed to determine that a condition presenting a potential threat to the integrity of the pipeline exists, as required by § 195.452(h)(2). In Section 2.0 of its IMP, Targa failed to provide details on or define the adequate information required to confirm discovery of a condition. This section copies the regulatory definition, with no additional details. The plan must provide details on circumstances which may constitute discovery of a condition. Therefore, Targa’s written integrity management plan was inadequate to assure safe operation of a pipeline facility in accordance with § 195.402(c)(3). Targa must revise its integrity management plan to describe the adequate information needed to determine discovery of a condition in accordance with § 195.452(h)(2). Response 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#

42023043NOA_Notice of Amendment_05042023_(22-234487)_text.pdf, page 3and 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 60 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 maintain documentation of the safety improvement costs associated with fulfilling this Notice of Amendment (preparation/revision of plans, procedures) and submit the total to Bryan Lethcoe, Director, Southwest region, Pipeline and Hazardous Materials Safety Administration. In correspondence concerning this matter, please refer to CPF 4- 2023-043-NOA and, for each document you submit, please provide a copy in electronic format whenever possible. Sincerely, Bryan Lethcoe Director, Southwest Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration Enclosure: Response Options for Pipeline Operators in Enforcement Proceedings cc: Bryan J. MacKenzie, Sr. Manager Pipeline Integrity, bmackenzie@targaresources.com Gregg Johnson, Director of Pipeline Compliance, gjohnson@targaresources.com#

42023043NOA_Closure Letter_08042023_(22-234487)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL August 04, 2023 G. Clark White Executive Vice President Operations Targa Downstream LLC 811 Louisiana Street Suite 2100 Houston, Texas 77002 CPF 4-2023-043-NOA Dear Mr. White: From February 22 to October 17, 2022, a representative from the Pipeline and Hazardous Materials Safety Administration (PHMSA), pursuant to chapter 601 of 49 United States Code U. S. C) inspected Targa Downstream Resources, LLC’s (Targa) integrity management plan and maintenance and operations procedures in Houston, Texas. On May 4, 2023, PHMSA Southwest Region issued the Notice, CPF 4-2023-043-NOA, to Targa requiring amendments of its integrity management plan. Targa submitted its amended procedures on July 6, 2023. PHMSA has reviewed the amended procedure, and it appears that the inadequacies outlined in this Notice have been corrected. This letter is to inform you no further action is necessary and this case is now closed. Thank you for your cooperation. Sincerely, Bryan Lethcoe Director, Southwest Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Bryan J. MacKenzie, Sr. Manager Pipeline Integrity, bmackenzie@targaresources.com Gregg Johnson, Director of Pipeline Compliance, gjohnson@targaresources.com#