# TARGA RESOURCES OPERATING LLC — Notice of Probable Violation - **operation:** document - **citation:** CPF 42024048NOPV - **title:** TARGA RESOURCES OPERATING LLC — Notice of Probable Violation - **source type:** enforcement - **agency:** Pipeline and Hazardous Materials Safety Administration - **status:** historical - **official:** true - **published on:** 2024-10-22 - **effective on:** Not available - **summary:** CLOSED notice of probable violation citing 195.402(a), 195.402(d)(5), 195.446(c)(3), 195.452(i)(4). - **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024048nopv.json - **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024048nopv.md - **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024048nopv - **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42024048NOPV **body:** Notice of Probable Violation involving TARGA RESOURCES OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a), 195.402(d)(5), 195.446(c)(3), 195.452(i)(4). The case was opened on 2024-10-22 and is reported as closed as of 2025-07-10. Open the official case record for notices, responses, orders, and the latest status. Official case documents: 42024048NOPV_Closure Letter_07102025_(23-264726).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024048NOPV/42024048NOPV_Closure%20Letter_07102025_(23-264726).pdf 42024048NOPV_Closure Letter_07102025_(23-264726)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024048NOPV/42024048NOPV_Closure%20Letter_07102025_(23-264726)_text.pdf 42024048NOPV_Final Order_07012025_(23-264726).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024048NOPV/42024048NOPV_Final%20Order_07012025_(23-264726).pdf 42024048NOPV_Final Order_07012025_(23-264726)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024048NOPV/42024048NOPV_Final%20Order_07012025_(23-264726)_text.pdf 42024048NOPV_Operator Response to Notice_11182024_(23-264726).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024048NOPV/42024048NOPV_Operator%20Response%20to%20Notice_11182024_(23-264726).pdf 42024048NOPV_PCO_10222024_(23-264726).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024048NOPV/42024048NOPV_PCO_10222024_(23-264726).pdf 42024048NOPV_PCO_10222024_(23-264726)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024048NOPV/42024048NOPV_PCO_10222024_(23-264726)_text.pdf 42024048NOPV_Final Order_07012025_(23-264726)_text.pdf July 1, 2025 VIA ELECTRONIC MAIL TO: mmeloy@targaresources.com Matthew Meloy Chief Executive Officer Targa Resources Operating, LLC 811 Louisiana Street Suite 2100 Houston, TX 77002 Re: CPF No. 4-2024-048-NOPV Dear Mr. Meloy: Enclosed please find the Final Order issued in the above-referenced case. It makes findings of violation and specifies actions that need to be taken to comply with the pipeline safety regulations. When the terms of the compliance order are completed, as determined by the Director, Southwest Region, this enforcement action will be closed. Service of the Final Order by e-mail is effective upon the date of transmission and acknowledgement of receipt as provided under 49 CFR § 190.5. Thank you for your cooperation in this matter. Sincerely, Linda Daugherty Acting Associate Administrator for Pipeline Safety Enclosures (Final Order and NOPV) cc: Bryan Lethcoe, Director, Southwest Region, Office of Pipeline Safety, PHMSA Gerald R. Shrader, Executive Vice President, General Counsel and Secretary, Targa Resources Corp., jshrader@targaresources.com Gregg Johnson, Director of Pipeline Compliance, Targa Resources Corp., gjohnson@targaresources.com John Laeger, Vice President of Senior G&P Operations, Targa Resources Corp., jlaeger@targaresources.com Julie Pabon, Senior Counsel, Targa Resources Corp., jpabon@targaresources.com CONFIRMATION OF RECEIPT REQUESTED U.S. DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION OFFICE OF PIPELINE SAFETY WASHINGTON, D.C. 20590 ____________________________________ In the Matter of ) Targa Resources Operating, LLC ) CPF No. 4-2024-048-NOPV ) ) ) Respondent. ) ____________________________________) FINAL ORDER On October 22, 2024 pursuant to 49 CFR § 190.207, the Director, Southwest Region, Office of Pipeline Safety (OPS), issued a Notice of Probable Violation (Notice) to Targa Resources Operating, LLC (Respondent). The Notice proposed finding that Respondent had violated the pipeline safety regulations in 49 CFR Part 195. The Notice also proposed certain measures to correct the violations. Respondent did not contest the allegations of violation or corrective measures. Based upon a review of all the evidence, pursuant to § 190.213, I find Respondent violated the pipeline safety regulation listed below, as more fully described in the enclosed Notice, which is incorporated by reference: 49 CFR § 195.452(a)(i)(4) (Item 3) ─ Respondent failed to conduct an Emergency Flow Restricting Device (EFRD) analysis to determine if an EFRD is needed on a pipeline segment that is located in, or which could affect, a high- consequence area in the event of a hazardous liquid pipeline release. This finding of violation will be considered a prior offense in any subsequent enforcement action taken against Respondent. Compliance Actions Pursuant to 49 U.S.C. § 60118(b) and 49 CFR § 190.217, Respondent is ordered to take the actions proposed in the enclosed Notice to correct the violation. The Director may grant an extension of time to comply with any of the required items upon a written request timely submitted by the Respondent and demonstrating good cause for an extension. Upon completion of the ordered actions, Respondent may request that the Director close the case. Failure to comply with this Order may result in the assessment of civil penalties under 49 CFR § 190.223 or in referral to the Attorney General for appropriate relief in a district court of the United States. Warning Items With respect to Items 1 and 2, the Notice alleged probable violations of 49 CFR §§ 195.402(d)(5) and 195.446(c)(3), respectively, but did not propose a civil penalty or compliance order for these items. Therefore, these are considered warning items. If OPS finds a violation of any of these items in a subsequent inspection, Respondent may be subject to future enforcement action. The terms and conditions of this order are effective upon service in accordance with 49 CFR § 190.5. ___________________________________ _________________________ Linda Daugherty Date Issued Acting Associate Administrator for Pipeline Safety NOTICE OF PROBABLE VIOLATION AND PROPOSED COMPLIANCE ORDER VIA ELECTRONIC MAIL TO: cwhite@targaresources.com October 22, 2024 Clark White Executive Vice President Targa Resources Operating, LLC 811 Louisiana, Suite 2100 Houston, Texas 77002 CPF 4-2024-048-NOPV Dear Mr. Clark: From February 27 to August 23, 2023, a representative of the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), pursuant to Chapter 601 of 49 United States Code (U.S.C.) inspected Targa Resources Operating, LLC’s (Targa) crude oil gathering system on the Fort Berthold Reservation in North Dakota. As a result of the inspection, it is alleged that you have committed probable violations of the Pipeline Safety Regulations, Title 49, Code of Federal Regulations (CFR). The items inspected and the probable violations are: 1. § 195.402 Procedural manual for operations, maintenance, and emergencies. (a) General. Each operator shall prepare and follow for each pipeline system a manual of written procedures for conducting normal operations and maintenance activities and handling abnormal operations and emergencies. This manual shall be reviewed at intervals not exceeding 15 months, but at least once each calendar year, and appropriate changes made as necessary to insure that the manual is effective. This manual shall be prepared before initial operations of a pipeline system commence, and appropriate parts shall be kept at locations where operations and maintenance activities are conducted. (b) . . . . (d) Abnormal operation. The manual required by paragraph (a) of this section must include procedures for the following to provide safety when operating design limits have been exceeded: (1) . . . . (5) Periodically reviewing the response of operator personnel to determine the effectiveness of the procedures controlling abnormal operation and taking corrective action where deficiencies are found. Targa failed to periodically review the response of operator personnel to determine the effectiveness of the procedures controlling abnormal operations and taking corrective action where deficiencies were found in accordance with § 195.402(a) and its procedures, Targa Hazardous Liquids OM&E – Abnormal Operations (Rev. 12/26/2007). Specifically, Targa failed to provide records demonstrating that the effectiveness reviews required by § 195.402(d)(5) occurred and that corrective actions were taken where deficiencies were found. 2. § 195.446 Control Room Management (a) . . . . (c) Provide adequate information. Each operator must provide its controllers with the information, tools, processes and procedures necessary for the controllers to carry out the roles and responsibilities the operator has defined by performing each of the following: (1) . . . . (3) Test and verify an internal communication plan to provide adequate means for manual operation of the pipeline safely, at least once each calendar year, but at intervals not to exceed 15 months; Targa failed to test and verify an internal communication plan to provide adequate means for manual operation of the pipeline safely, at least once each calendar year, but at intervals not to exceed 15 months in accordance with § 195.446(c)(3) and Targa’s Control Room Management Plan, Badlands Pipeline Control Center Internal Communication Plan (08/15/23; Rev. 2.0), section 1. Specifically, Targa failed to provide records demonstrating that a test of the internal communication plan occurred in 2017, 2018, 2019, 2021, and 2022. 3. § 195.452 Pipeline integrity management in high consequence areas. (a) . . . . (i) What preventive and mitigative measures must an operator take to protect the high consequence area? (1) . . . . (4) Emergency Flow Restricting Devices (EFRD). If an operator determines that an EFRD is needed on a pipeline segment that is located in, or which could affect, a high-consequence area (HCA) in the event of a hazardous liquid pipeline release, an operator must install the EFRD. In making this determination, an operator must, at least, evaluate the following factors - the swiftness of leak detection and pipeline shutdown capabilities, the type of commodity carried, the rate of potential leakage, the volume that can be released, topography or pipeline profile, the potential for ignition, proximity to power sources, location of nearest response personnel, specific terrain within the HCA or between the pipeline segment and the HCA it could affect, and benefits expected by reducing the spill size. An RMV installed under this paragraph (i)(4) must meet all of the other applicable requirements in this part, provided that the requirement of this sentence does not apply to gathering lines. Targa failed to conduct an Emergency Flow Restricting Device (EFRD) analysis to determine if an EFRD is needed on a pipeline segment that is located in, or which could affect, a high- consequence area (HCA) in the event of a hazardous liquid pipeline release in accordance with § 195.452(i)(4). Specifically, Targa failed to update its existing EFRD analysis or conduct a new analysis after Targa converted an 8-inch gas gathering line that affected an HCA into a regulated hazardous liquid gathering pipeline. On May 7, 2019, Targa notified PHMSA of a project to convert an 8-inch gas gathering pipeline into a regulated hazardous liquid gathering pipeline. According to a document provided by Targa, “SAC – Roberts Trust to Johnson’s High Pressure Line Conversion Project” (Rev. A; June 4, 2019), the converted hazardous liquid gathering pipeline includes segments that are located in or could affect an HCA. Targa provided its EFRD analysis, “Badlands Crude Oil Pipeline System Leak Detection and EFRD Analysis” (2018). However, Targa failed to include the 8-inch converted hazardous liquid gathering line in this analysis, or conduct a new analysis. Therefore, Targa failed to conduct an EFRD analysis to determine if an EFRD is needed on a pipeline segment that is located in, or which could affect, an HCA in the event of a hazardous liquid pipeline release in accordance with § 195.452(i)(4). Proposed Civil Penalty Under 49 U.S.C. § 60122 and 49 CFR § 190.223, you are subject to a civil penalty not to exceed $266,015 per violation per day the violation persists, up to a maximum of $2,660,135 for a related series of violations. For violation occurring on or after January 6, 2023 and before December 28, 2023, the maximum penalty may not exceed $257,664 per violation per day the violation persists, up to a maximum of $2,576,627 for a related series of violations. For violation occurring on or after March 21, 2022 and before January 6, 2023, the maximum penalty may not exceed $239,142 per violation per day the violation persists, up to a maximum of $2,391,412 for a related series of violations. For violation occurring on or after May 3, 2021 and before March 21, 2022, the maximum penalty may not exceed $225,134 per violation per day the violation persists, up to a maximum of $2,251,334 for a related series of violations. For violation occurring on or after January 11, 2021 and before May 3, 2021, the maximum penalty may not exceed $222,504 per violation per day the violation persists, up to a maximum of $2,225,034 for a related series of violations. For violation occurring on or after July 31, 2019 and before January 11, 2021, the maximum penalty may not exceed $218,647 per violation per day the violation persists, up to a maximum of $2,186,465 for a related series of violations. For violation occurring on or after November 27, 2018 and before July 31, 2019, the maximum penalty may not exceed $213,268 per violation per day, with a maximum penalty not to exceed $2,132,679. We have reviewed the circumstances and supporting documents involved in this case, and have decided not to propose a civil penalty assessment at this time. Proposed Compliance Order With respect to Item 3 pursuant to 49 U.S.C. § 60118, the Pipeline and Hazardous Materials Safety Administration proposes to issue a Compliance Order to Targa Resources Operating LLC. Please refer to the Proposed Compliance Order, which is enclosed and made a part of this Notice. Warning Items With respect to Items 1 and 2 we have reviewed the circumstances and supporting documents involved in this case and have decided not to conduct additional enforcement action or penalty assessment proceedings at this time. We advise you to promptly correct these items. Failure to do so may result in additional enforcement action. Response to this Notice Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement Proceedings. Please refer to this document and note the response options. All material you submit in response to this enforcement action may be 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 your receipt of this Notice, you have 30 days to respond as described in the enclosed Response Options. 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 a Final Order. If you are responding to this Notice, we propose that you submit your correspondence to my office within 30 days from receipt of this Notice. The Region Director may extend the period for responding upon a written request timely submitted demonstrating good cause for an extension. In your correspondence on this matter, please refer to CPF 4-2024-048-NOPV 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 Enclosures: Proposed Compliance Order Response Options for Pipeline Operators in Enforcement Proceedings cc: Gregg Johnson, Director of Pipeline Compliance, gjohnson@targaresources.com Alfred Garcia, Manager Pipeline Compliance, Alfred.garcia@targaresources.com PROPOSED COMPLIANCE ORDER Pursuant to 49 United States Code § 60118, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposes to issue to Targa Resources Operating LLC (Targa), a Compliance Order incorporating the following remedial requirements to ensure the compliance of Targa with the pipeline safety regulations: A. B. In regard to Item 3 of the Notice pertaining to Targa’s failure to conduct an Emergency Flow Restricting Devices (EFRD) analysis to determine if an EFRD is needed on a pipeline segment that is located in, or which could affect, an HCA in the event of a hazardous liquid pipeline release, Targa must conduct an EFRD analysis that considers all pipelines that could affect an HCA, including the 8-inch converted hazardous liquid gathering pipeline and provide the analysis to the Director, Southwest Region, PHMSA within 60 days of receipt of the Final Order. It is requested (not mandated) that Targa maintain documentation of the safety improvement costs associated with fulfilling this Compliance Order and submit the total to Bryan Lethcoe, Director, Southwest Region, Pipeline and Hazardous Materials Safety Administration. It is requested that these costs be reported in two categories: 1) total cost associated with preparation/revision of plans, procedures, studies and analyses, and 2) total cost associated with replacements, additions and other changes to pipeline infrastructure. 42024048NOPV_Closure Letter_07102025_(23-264726)_text.pdf VIA ELECTRONIC MAIL TO: mmeloy@targaresources.com July 10, 2025 Matthew Meloy Chief Executive Officer Targa Resources Operating, LLC 811 Louisiana Street Suite 2100 Houston, TX 77002 RE: CPF 4-2024-048-NOPV Dear Mr. Meloy: On July 1, 2025, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued to Targa Resources Operating, LLC’s (Targa) a Final Order. Based on our review of the documentation you provided, it has been determined that you have complied with the terms of this Order. Accordingly, this case is now closed and no further action is necessary with respect to the matters involved in this case. Thank you for your cooperation in this matter. Sincerely, Bryan Lethcoe Director, Southwest Region, Office of Pipeline Safety Pipeline and Hazardous Materials Safety Administration cc: Gregg Johnson, Director of Pipeline Compliance, Targa Resources Operating, LLC, gjohnson@targaresources.com Alfred Garcia, Manager Pipeline Compliance, Targa Resources Operating, LLC, alfred.garcia@targaresources.com Julie Pabon, Senior Counsel, Targa Resources Operating, LLC, jpabon@targaresources.com John Laeger, Senior VP G&P Operations, Targa Resources Operating, LLC, jlaeger@targaresources.com - **truncated:** false - **body characters:** 19032