# TARGA RESOURCES OPERATING LLC — Notice of Amendment

- **operation:** document
- **citation:** CPF 42024049NOA
- **title:** TARGA RESOURCES OPERATING LLC — Notice of Amendment
- **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 amendment citing 195.402(a), 195.402(c)(3), 195.420(a).
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024049noa.json
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- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-42024049noa
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/42024049NOA
**body:**

Notice of Amendment involving TARGA RESOURCES OPERATING LLC. PHMSA's enforcement data identifies the cited regulations as 195.402(a),  195.402(c)(3),  195.420(a). The case was opened on 2024-10-22 and is reported as closed as of 2024-11-26. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

42024049NOA_Closure Letter_11262024_(23-264726).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024049NOA/42024049NOA_Closure%20Letter_11262024_(23-264726).pdf

42024049NOA_Closure Letter_11262024_(23-264726)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024049NOA/42024049NOA_Closure%20Letter_11262024_(23-264726)_text.pdf

42024049NOA_Notice of Amendment_10222024_(23-264726).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024049NOA/42024049NOA_Notice%20of%20Amendment_10222024_(23-264726).pdf

42024049NOA_Notice of Amendment_10222024_(23-264726)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024049NOA/42024049NOA_Notice%20of%20Amendment_10222024_(23-264726)_text.pdf

42024049NOA_Operator Response to Notice_11182024_(23-264726).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42024049NOA/42024049NOA_Operator%20Response%20to%20Notice_11182024_(23-264726).pdf

42024049NOA_Notice of Amendment_10222024_(23-264726)_text.pdf

NOTICE 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:



(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.



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-
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

VIA 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
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