{"operation":"document","citation":"CPF 42025059NOPSO","title":"TARGA DOWNSTREAM LLC — Safety Order","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"current","official":true,"published_on":"2025-12-08","effective_on":null,"summary":"OPEN safety order.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025059nopso.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025059nopso.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-42025059nopso","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/42025059NOPSO","body":"Safety Order involving TARGA DOWNSTREAM LLC. The dataset does not identify a cited regulation for this case. The case was opened on 2025-12-08 and is reported as open. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n42025059NOPSO_Notice of Proposed Safety Order_12082025_(25-355374).pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025059NOPSO/42025059NOPSO_Notice%20of%20Proposed%20Safety%20Order_12082025_(25-355374).pdf\n\n42025059NOPSO_Notice of Proposed Safety Order_12082025_(25-355374)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/42025059NOPSO/42025059NOPSO_Notice%20of%20Proposed%20Safety%20Order_12082025_(25-355374)_text.pdf\n\n42025059NOPSO_Notice of Proposed Safety Order_12082025_(25-355374)_text.pdf\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration 8701 S. Gessner, Suite 630\nHouston TX 77074\nVIA ELECTRONIC MAIL TO: mmeloy@targaresources.com\nDecember 8, 2025\nMatthew Meloy\nChief Executive Officer\nTarga Resources, LLC\n811 Louisiana Street\nSuite 2100\nHouston, Texas 77002\nCPF No. 4-2025-059-NOPSO\nDear Mr. Meloy:\nEnclosed is a Notice of Proposed Safety Order (Notice) issued in the above-referenced case. The\nNotice proposes that Targa Resources, LLC, take certain measures with respect to its Wildcat\nJunction pump station in Winkler County, Texas, to ensure pipeline safety. Your options for\nresponding are set forth in the Notice. Service of this Notice by electronic mail is deemed effective\nupon the date of transmission and acknowledgment of receipt, or as otherwise provided under 49\nCFR § 190.5.\nWe look forward to a successful resolution to ensure pipeline safety. Please direct any questions\non this matter to me at (713) 773-7215.\nSincerely,\nBryan Lethcoe\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Notice of Proposed Safety Order\nCopy of 49 C.F.R. § 190.239\nCc: Linda Daugherty, Deputy Associate Administrator for Field Operations, OPS\nJordan North, Specialist ES&H, Targa Resources, LLC,\njnorth@targaresources.com\n\n\n\nGregg Johnson, Director of Pipeline Compliance, Targa Resources LLC,\ngjohnson@targaresources.com\nKyle Kubin, Sr. Vice President, Operations & Engineering, Targa Resources,\nLLC, kkubin@targaresources.com\nMatthew Hawthorne, Deputy General Counsel, Targa Resources, LLC,\nMhawthorne@targaresources.com\n2\n\n\n\nDEPARTMENT OF TRANSPORTATION\nPIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION\nOFFICE OF PIPELINE SAFETY\nSOUTHWEST REGION\nHOUSTON, TEXAS\n____________________________________\n)\nIn the Matter of )\n)\nTarga Resources, LLC, ) CPF No. 4-2025-059-NOPSO\n)\nRespondent )\n____________________________________)\nNOTICE OF PROPOSED SAFETY ORDER\nIntroduction and Purpose\nThe Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety\n(OPS), is issuing this Notice of Proposed Safety Order (NOPSO or Notice) to Targa Resources,\nLLC (Targa or Respondent) pursuant to the authority provided in 49 U.S.C. § 60117 and 49 CFR\n§ 190.239. As explained in more detail below, PHMSA has initiated an investigation of an\naccident that occurred on October 16, 2025, at Targa’s Wildcat Junction Pump Station (Wildcat\nJunction PS) in Winkler County, Texas. Three employees of a third-party contractor, K&K Inc.,\nwere injured during the accident, two of whom were hospitalized and one of whom remains in\ncritical condition. The accident also resulted in the release of 6.4 barrels of natural gas liquids\n(NGLs). The Wildcat Junction PS is a hazardous liquid pipeline facility subject to PHMSA’s\njurisdiction pursuant to the Pipeline Safety Act, 49 U.S.C. § 60101 et seq., and Pipeline Safety\nRegulations, 49 CFR Parts 190 to 199.\nPHMSA’s ongoing investigation indicates that conditions may exist at the Wildcat Junction PS\nthat pose a pipeline integrity risk to public safety, property, or the environment. Specifically, the\ninvestigation indicates that Targa does not have appropriate controls in place to supervise the work\nof personnel performing operations and maintenance activities, that Targa’s failure to adequately\nsupervise the work of those personnel has coincided with multiple safety-related incidents and\nrisks at the Wildcat Junction PS, and that the absence of these controls is creating an ongoing\nsafety risk for Targa personnel and an integrity risk for the hazardous liquid pipeline facilities at\nthe Wildcat Junction PS. The purpose of this NOPSO is to provide Targa with notice of the\npreliminary findings of PHMSA’s ongoing investigation and to propose the corrective measures\nthat can be taken to ensure that the public, property, and the environment are protected from this\npipeline integrity risk.\n3\n\n\n\nBackground\nThe Wildcat Junction PS is part of the Grand Prix West pipeline system, which transports natural\ngas liquids (NGLs) from Ramsey Meter Station in Reeves County, TX to PS8 Junction in Johnson\nCounty, TX. The Grand Prix West pipeline system includes the 16-inch GPX-B pipeline, the 20-\ninch GPX-C pipeline, and the 24-inch GPX-D pipeline. The Wildcat Junction PS, which is located\nin Winkler County, Texas, receives NGLs from the 16-inch GPX-B pipeline and delivers NGLs\ninto the 20-inch GPX-C pipeline.\nOn the morning of October 16, 2025, an accident occurred at the Wildcat Junction PS that injured\nthree employees of K&K Inc., a third-party contractor, who were performing onsite operations and\nmaintenance activities for Targa. Two of the employees were taken to the hospital, and one\nremains in critical condition. Targa notified the National Response Center (NRC) of the accident\nlater that day, and PHMSA responded by initiating an investigation. Targa’s NRC notification\nestimated the size of the NGL release at 6.4 barrels. The preliminary findings of that investigation\nare as follows.\nPreliminary Findings\n• The Wildcat Junction PS is part of the Grand Prix West pipeline system. The Grand\nPrix West pipeline system includes the 16-inch GPX-B pipeline, the 20-inch GPX-C\npipeline, and the 24-inch GPX-D pipeline. These three pipelines are connected in a\nseries and transport NGLs in an easterly direction from Ramsey Meter Station in\nReeves County, TX to PS8 Junction in Johnson County, TX. The Wildcat Junction PS\nreceives NGLs from the 16-inch GPX-B pipeline and delivers NGLs into the 20-inch\nGPX-C pipeline.\n• The Wildcat Junction PS is a new facility that receives NGLs from the 16-inch GPX-\nB pipeline and delivers NGLs into the 20-inch GPX-C pipeline. The Wildcat Junction\nPS includes four pump units (#110, #125, #140, and #155). Targa completed the\ncommissioning of these four pump units on October 14, 2025.\nFrom October 15 to October 16, 2025, Targa’s operations team conducted a series of\ntroubleshooting activities to bring the pump units online.\n• On October 16, 2025, Targa’s operations team brought Rockwell Automation (a pump\nautomation vendor) onsite to assist with ongoing troubleshooting activities. While\nattempting to bring pump units #140 and 155 online. a 3rd party inspector from TKO\nField Services, along with a construction crew from K&K Inc., Targa’s construction\ncontractor, accessed the hinge pin cap on the check valve on the 30-inch system to\ncheck the position of the “flapper.” A flapper in a check valve acts as a one-way gate\n4\n\n\n\nthat allows fluid to flow in a single direction while preventing it from flowing\nbackward.\n• The valve hinge pin cap has a different design on the 12-inch and 30-inch station piping\ncheck valve systems. The valve’s hinge pin cap may or may not be a pressure-retaining\npart of the valve. In this case, the 30-inch check valve is equipped with a safely\nremovable hinge pin cap that can be accessed during pressurization, whereas the 12-\ninch check valve does not have a safely removable hinge pin cap during pressurization.1\n• The foreman from K&K removed the bolts on the hinge pin cap on the 12-inch check\nvalve. This 12-inch line was pressurized at the time of the accident.2\n• At approximately 9:53am on October 16, 2025, the pump station’s emergency\nshutdown (ESD) system triggered an alarm based on detected gas. At the same time,\nTarga personnel in a nearby construction trailer heard a commotion outside. The Targa\npersonnel responded to the area and saw a vapor cloud near the pump unit #110 on the\n12-inch line. The valve’s hinge pin and its cap had ejected and injured three contractor\npersonnel onsite.\n• At approximately 9:54 AM, an individual at the scene called 911. Two of the injured\npersonnel were taken to the hospital by ambulance. One person took himself to the\nhospital to get checked out because he had inhaled the fumes from the released product.\nTwo of the individuals were discharged from the hospital, although one of them was\nlater readmitted. One individual is still in critical condition and hospitalized in\nLubbock, TX.\n• According to Targa, operator personnel were not aware that the contractor crew was\nworking within the facility on October 16, 2025, even though the contractor crew had\nbeen issued a Job Safety Analysis (JSA) work permit.\n• PHMSA’s preliminary investigation indicated that Targa did not maintain an accurate\nlist of personnel onsite on October 16, 2025. Once PHMSA raised concerns about\npotential incomplete personnel list, Targa resubmitted a revised personnel list for\nOctober 16, 2025.\n• PHMSA’s interviews and review of daily safety reports discovered evidence of\nmultiple safety incidents and near misses on the construction project prior to the\n1 PHMSA has not been provided with any additional information on the manufacturing specifications of these 12-\ninch and 30-inch valves.\n2 In the course of its investigation, PHMSA received from Targa a copy of a Job Safety Analysis work permit which\nauthorized the K&K crew to perform leak checks and startup assistance on October 16.5\n\n\n\naccident on October 16, 2025. The daily safety reports noted incidents where valves\nimpacted the ground while being unloaded, where damage was discovered on facility\ncomponents with no clear origin or culprit for the damage, and where equipment fell\nand injured construction employees.\n• Several witnesses informed PHMSA that K&K had previously performed unsafe\noperations on the project, including jack hammering near an active NGL line and\nattempting to lift an active NGL pipeline with a sling to be placed on I-beam supports.\nHowever, neither of these incidents were recorded as near misses or recordables in\ndaily safety reporting.\n• Targa’s Pipeline superintendent had previously instructed K&K to suspend unsafe\noperations. K&K continued to work on the site and it is unclear whether corrective\nmeasures were put in place by Targa to ensure such unsafe operations did not recur.\n• There was no lock or other gate security at the construction project, allowing\nunauthorized access at the site.\n• Records provided to PHMSA after the accident indicated that none of the individuals\non the K&K crew were OQ-qualified to perform work on the valve.\n• The Wildcat Junction PS is now shut-in and isolated, but the mainline is still in service.\n• The investigation of the Failure is on-going, and information could change. These\npreliminary findings may be amended based on further findings during the\ninvestigation.\nProposed Issuance of Safety Order\nSection 60117(m) of Title 49, United States Code, provides for the issuance of a safety order, after\nreasonable notice and the opportunity for a hearing, requiring corrective measures, which may\ninclude physical inspection, testing, repair, or other action, as appropriate. The basis for making\nthe determination that a pipeline facility has a condition or conditions that pose a pipeline integrity\nrisk to public safety, property, or the environment is set forth both in the above-referenced statute\nand 49 CFR § 190.239, a copy of which is enclosed.\nAfter evaluating the foregoing preliminary findings of fact, and having considered the\ncharacteristics of the Wildcat Junction PS, including pressures necessary to transport the products;\nthe hazardous nature of the products, natural gas liquids, which are flammable and toxic; the recent\nhistory of unsafe construction and operations activities at the Wildcat Junction PS; the failure by\nTarga to adequately monitor work and exercise control of work at the Wildcat Junction PS; the\nuncertainty as to the root cause or causes of the accident; and the possibility that the same root\ncauses of the accident may continue at the Wildcat Junction PS and could lead to additional6\n\n\n\naccidents, it appears that the continued operation of the Wildcat Junction pump station without\ncorrective measures would pose a pipeline integrity risk to public safety, property, or the\nenvironment. Accordingly, corrective measures are necessary to mitigate the pipeline integrity risk\nof the pipeline system to protect public safety, property, and the environment.\nAccordingly, PHMSA issues this Notice of Proposed Safety Order to notify Respondent of the\nproposed issuance of a safety order and to propose that Respondent take measures specified herein\nto address the potential risk.\nProposed Corrective Measures\n“Affected Segment” – The “Affected Segment” means the 12-inch station piping and valve feeding\ninto the pump unit #110, all piping, pump units, measurement facilities, and appurtenant facilities\nat Wildcat Junction PS.\n\"Affected Facility\" – The \"Affected Facility\" means all station piping, pump units, measurement\nfacilities, valves, actuators, control devices, pressure relief devices, SCADA equipment, sensors,\nfabricated assemblies, and appurtenant facilities at the Wildcat Junction PS in Winkler County,\nTexas.\nDirector – The \"Director\" means the Director, PHMSA, Office of Pipeline Safety, Southwest\nRegion. The Director’s address is 8701 South Gessner Road, Suite 630, Houston, TX 77074.\nPursuant to 49 U.S.C. § 60117(m) and 49 CFR § 190.239, PHMSA proposes to issue to Targa a\nsafety order incorporating the following remedial requirements with respect to the affected\npipeline.\n1. Root Cause Failure Analysis. Within 60 days following issuance of the Safety Order,\ncomplete a root cause failure analysis (RCFA) and submit a final report of this RCFA\nto the Director. The RCFA must be supplemented or facilitated by an independent\nthird-party acceptable to the Director and must document the decision-making process\nand all factors contributing to the failure. Respondent must ensure that all reports,\nwhether draft or final, are made available in their entirety to the Director at the same\ntime they are made available to Respondent. The final report must include findings\nand any lessons learned and whether the findings and any lessons learned are applicable\nto other locations within Targa’s pipeline system.\n2. Repair Plan. Within 90 days following issuance of the Safety Order, the following\ninformation must be submitted in writing to the Director.\na. Targa must submit detailed repair plans for the Affected Segment, to ensure\nthat it meets the requirements of 49 CFR § 195.422.\nb. The Repair Plan must specify how the Affected Facility will be protected\nfrom unauthorized entry in accordance with 49 CFR § 195.436. The Repair7\n\n\n\nPlan must include security patrolling for the Affected Facility and identify\nthe methods and frequencies of such patrols.\nc. The Director may approve the Repair Plan incrementally without approving\nthe entire plan.\nd. Once approved by the Director, the Repair Plan will be incorporated by\nreference into this Order.\ne. The Repair Plan must specify in detail the procedures and plans to bring the\npump units back in service. The Repair Plan must include the list of\npersonnel that are qualified under the provisions of 49 CFR 195 Subpart G\nto perform work under the Repair Plan. This should include the roles and\nresponsibilities of the personnel during the restart. The Repair Plan must\nspecify the Targa control center points of contact and include the control\nroom’s shift change information. A copy of the shift change information\nmust be provided daily to the Director until the Repair Plan is completed.\nf. The Repair Plan must identify and specify the position of each valve in\nthe Affected Facility, the positions confirmed with the control center, and\nwritten documentation of the valve positions and control center\nconfirmation provided to the Director during the completion of the repairs.\ng. The Repair Plan must include a description of the communications process\nwith the control center and the Management of Change procedures,\nincluding documentation, that will be used for any changes made to the\noperating system, including all operational and pressure restrictions. The\nRestart Plan must also identify how any operation issues will be\ncommunicated between the control center and Targa’s operations team,\nincluding identifications of specific personnel.\nh. The Repair Plan must be implemented only during daylight hours and\ninclude sufficient in-person monitoring to ensure no abnormal operations\noccur.\ni. The Repair Plan must include advance communications with local\nemergency response officials.\nj. The Repair Plan must include a review of the Affected Facility for any\nabnormal operating conditions. Targa must address any findings that require\nremedial measures to be implemented.\n3. Emergency Response Procedures. Within 60 days following issuance of the Safety\nOrder, Targa must submit to the Director documentation of a review of its emergency\n8\n\n\n\nresponse procedures with personnel involved in operating the Wildcat Junction PS\nincluding identification of previous deficiencies, to ensure all operating personnel are\nprepared to respond appropriately. Documentation of the review must include signed\nattendance sheets noting the date of the meeting and copies of any materials presented\nor provided during the review.\n4. Control of Work and Management of Change Procedures. Within 60 days following\nissuance of the Safety Order, Targa must submit its complete Control of Work and\nManagement of Change procedures to the Director for review and approval. The\nOperator must review its Control of Work and Management of Change procedures with\npersonnel involved in operating the Wildcat Junction PS, identify deficiencies, and\nensure all operating personnel are prepared to execute these procedures.\n5. Construction, Commissioning, and Startup Procedures. Within 120 days following\nissuance of the Safety Order, Targa must submit to the Director for approval a review\nof all Construction, Commissioning, and Startup Procedures and associated training\nrequirements to reduce accidents resulting from startup issues and operator errors.\nTarga must complete modifications to its Construction, Commissioning, and Startup\nProcedures and submit a redlined version of the revised procedures showing the\nchanges to the Director for review and approval.\n6. Operations and Maintenance Procedures and Operator Qualifications. Within 120\ndays following issuance of the Safety Order, Targa must submit to the Director for\napproval a review of its written Operations and Maintenance Procedures and Operator\nQualification Program to identify deficiencies or inadequacies that cause or contribute\nto safety risks and corresponding programmatic changes or actions aimed at eliminating\nsafety risks. This review must include, but is not limited to, all Operations and\nMaintenance Procedures and associated training requirements to reduce accidents\nresulting from maintenance issues and operator errors. In addition, Targa must perform\na complete review of its Operator Qualification Program including procedures, covered\ntasks, training requirements, qualification and re-qualification requirements, span of\ncontrol, and Abnormal Operating Conditions. Targa must complete modifications to its\nOperating and Maintenance Procedures and Operator Qualification Program and\nsubmit a redlined version of the revised procedures showing the changes to the Director\nfor review and approval.\nOther Requirements:\n1. Approvals. With respect to each submission under the Safety Order that requires the\napproval of the Director, the Director may: (a) approve, in whole or part, the\nsubmission; (b) approve the submission on specified conditions; (c) modify the\nsubmission to cure any deficiencies; (d) disapprove in whole or in part, the submission,\ndirecting that Respondent modify the submission, or (e) any combination of the above.\nIn the event of approval, approval upon conditions, or modification by the Director,\n9\n\n\n\nRespondent shall proceed to take all action required by the submission as approved or\nmodified by the Director. If the Director disapproves all or any portion of the\nsubmission, Respondent must correct all deficiencies within the time specified by the\nDirector and resubmit it for approval.\n2. Extensions of Time. The Director may grant an extension of time for compliance with\nany of the terms of the Safety Order upon a written request timely submitted\ndemonstrating good cause for an extension.\n3. Reporting. Submit quarterly reports to the Director that: (1) include all available data\nand results of the testing and evaluations required by this Order; and (2) describe the\nprogress of the repairs or other remedial actions being undertaken. The first quarterly\nreport is due on April 1, 2025. The Director may change the interval for the submission\nof these reports.\n4. Documentation of the Costs. It is requested that Respondent maintain documentation\nof the costs associated with implementation of the Safety Order. Include in each\nmonthly report submitted, the to-date total costs associated with: (1) preparation and\nrevision of procedures, studies and analyses; (2) physical changes to pipeline\ninfrastructure, including repairs, replacements and other modifications; and (3)\nenvironmental remediation.\nThe actions proposed by this Notice of Proposed Safety Order are in addition to and do not waive\nany requirements that apply to Respondent’s pipeline system under 49 CFR Parts 190 through 199,\nunder any other order issued to Respondent under authority of 49 U.S.C. § 60101 et seq., or under\nany other provision of Federal or state law.\nAfter receiving and analyzing additional data in the course of this proceeding and implementation\nof the corrective measures, PHMSA may identify other safety measures that need to be taken. In\nthat event, Respondent will be notified of any proposed additional measures and, if necessary,\namendments to the Safety Order.\nResponse to this Notice\nIn accordance with § 190.239, you have 30 days following receipt of this Notice to submit a written\nresponse to the official who issued the Notice. If you do not respond within 30 days, this\nconstitutes a waiver of your right to contest this Notice and authorizes the Associate Administrator\nfor Pipeline Safety to find facts as alleged in this Notice without further notice to you and to issue\na Safety Order. In your response, you may notify that official that you intend to comply with the\nterms of the Notice as proposed, or you may request that an informal consultation be scheduled\n(you will also have the opportunity to request an administrative hearing before a safety order is\nissued). Informal consultation provides you with the opportunity to explain the circumstances\nassociated with the risk condition(s) alleged in the notice and, as appropriate, to present a proposal\n10\n\n\n\nfor a work plan or other remedial measures, without prejudice to your position in any subsequent\nhearing.\nIf as a result of the informal consultation, you and PHMSA agree on a plan and schedule for you\nto address each identified risk condition, we may enter into a written consent agreement (PHMSA\nwould then issue an administrative consent order incorporating the terms of the agreement). If a\nconsent agreement is not reached, or if you have elected not to request informal consultation, you\nmay request an administrative hearing in writing within 30 days following receipt of the Notice or\nwithin 10 days following the conclusion of an informal consultation that did not result in a consent\nagreement, as applicable. Following a hearing, if the Associate Administrator finds the facility to\nhave a condition that poses a pipeline integrity risk to the public, property, or the environment in\naccordance with § 190.239, the Associate Administrator may issue a safety order.\nBe advised that all material you submit in response to this enforcement action is subject to being\nmade publicly available. If you believe that any portion of your responsive material qualifies for\nconfidential treatment under 5 U.S.C. 552(b), along with the complete original document you must\nprovide a second copy of the document with the portions you believe qualify for confidential\ntreatment redacted and an explanation of why you believe the redacted information qualifies for\nconfidential treatment under 5 U.S.C. 552(b).\nIn your correspondence on this matter, please refer to CPF No. 4-2025-059-NOPSO and for each\ndocument you submit, please provide a copy in electronic format whenever possible.\n___________________________________ _______________\nBryan Lethcoe Date issued\nDirector, Southwest Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\n11","truncated":false,"body_characters":25325}