TARGA RESOURCES OPERATING LLC — Notice of Amendment

party submissionOfficial PDF42024049NOA_Operator Response to Notice_11182024_(23-264726).pdf#

42024049NOA_Notice of Amendment_10222024_(23-264726)_text.pdf, page 1Official PDFNOTICE OF AMENDMENT 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 4-2024-049-NOA 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 Operation, LLC’s (Targa) procedures for maintenance and operations for its crude oil gathering system on the Fort Berthold Reservation in North Dakota. As a result of the inspection, PHMSA has identified the apparent inadequacy found within Targa’s plans or procedures. The item inspected and the inadequacy are described below: 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) . . . . (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:#

42024049NOA_Notice of Amendment_10222024_(23-264726)_text.pdf, page 2(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. § 195.420 Valve maintenance. (a) Each operator shall maintain each valve that is necessary for the safe operation of its pipeline systems in good working order at all times. Targa’s written procedures for conducting operations and maintenance activities were inadequate to provide for safe operation of a pipeline facility in accordance with § 195.402(c)(3). Specifically, Targa’s written procedures failed to identify valves necessary for the safe operation of its pipeline system. Identification of these valves in an operator’s written procedures is necessary to operate, maintain, and repair its pipeline system in accordance with § 195.420(a). Targa must amend its procedures to identify and designate the valves necessary for the safe operation of its pipeline facility. 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 Enforcement 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.#

42024049NOA_Notice of Amendment_10222024_(23-264726)_text.pdf, page 3It 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- 2024-049-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: Gregg Johnson, Director of Pipeline Compliance, gjohnson@targaresources.com Alfred Garcia, Manager Pipeline Compliance, Alfred.garcia@targaresources.com#

42024049NOA_Closure Letter_11262024_(23-264726)_text.pdf, page 1Official PDFVIA ELECTRONIC MAIL TO: jlaeger@targaresources.com November 26, 2024 John Laeger VP Senior G&P Operations Targa Resources Operating, LLC 110 W. 7th St, Suite 2300 Tulsa, Oklahoma 74119 RE: CPF 4-2024-049-NOA Dear Mr. Laeger: From February 27 to August 23, 2023, of the on-site inspection, 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) procedures regarding its crude oil gathering system on the Fort Berthold Reservation in North Dakota. As a result of the inspection, Targa was issued a Notice of Amendment on October 22, 2024, which proposed amendment of Targa’s operations and maintencance procedures. Targa submitted its amended procedures on November 18, 2024. My staff has reviewed the amended procedures, and it appears that the inadequacies outlined in this Notice of Amendment 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: Gregg Johnson, Director of Pipeline Compliance, gjohnson@targaresources.com Alfred Garcia, Manager Pipeline Compliance, alfred.garcia@targaresources.com Julie Pabon, Senior Counsel, jpabon@targaresources.com#