houstonlogo rjilogo

The Right-to-Know Network

Back to search

Gillis Gas Plant

Parent Companies:
Targa Resources Corp.
EPA Facility ID:
100000016234
Other ID:
LAD000757302
Facility DUNS:
174941534
Parent Company DUNS:
0

Location:

Address:
3807 Luke Powers Road
Lake Charles, LA 70615
County:
CALCASIEU
Lat / Long:
30.273, -93.157 (Get map)
Method:
Interpolation - Photo
Description:
Center of Facility
Horizonal accuracy:
25 m
Horizontal reference datum:
North American Datum of 1983
Source map scale:
24000

Owner/Operator:

Name:
Targa Midstream Services
Phone:
(713) 584-1000
Address:
811 Louisiana
Suite 2100
Houston, TX 77002
Foreign Address:

Person responsible for RMP implementation:

Name:
Greg Stracner
Title:
Area Manager

Emergency contact:

Name:
Greg Stracner
Title:
Area Manager
Phone:
(337) 583-5212
24-hour phone:
(337) 540-7863
Ext or PIN:

Other contacts:

Facility (or company) email:
Facility phone:
Facility (or company) URL:

Safety:

Local Emergency Planning Committee:
Calcasieu Parish LEPC
Full-Time Equivalent Employees:
17
Covered by OSHA PSM:
Yes
EPCRA section 302:
Yes
CAA Title Air Operating Permit:
No
CAA Permit ID#:
OSHA Star/Merit Ranking
No
Last Safety Inspection Date:
June 6, 2011
Inspecting Agency:
State environmental agency
Using Predictive Filing:
No

Processes:

Unspecified process
RMP ID:
1000055168
CBI claimed:
No
Program Level:
3
NAICS:
Natural Gas Liquid Extraction (211112)
Chemical name
CAS#
Quantity (lbs.)
CBI
Propane
74-98-6
740,000
No
Butane
106-97-8
630,000
No
Isobutane [Propane, 2-methyl]
75-28-5
600,000
No
Flammable Mixture
00-11-11
170,000
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No
Public OCA Chemical
0
No

RMP Preparer:

Name:
Greg Lewis
Address:
8556 Katy Freeway, Suite 124
Houston, TX 77024
Foreign Address:

Phone:
(713) 476-9958

Latest RMP Submission:

Date:
June 18, 2014
Type:
Resubmission
Reason:
5-year update (40 CFR 68.190(b)(1))
Registered:
Yes
RMP ID:
1000044632

Deregistration:

Date:
Effective Date:
Reason:
Other Reason:

2. Toxics: Worst-case

None

3. Toxics: Alternative release

None

4. Flammables: Worst-case

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Unspecified process)
CBI claimed:
No
Model used:
EPA's RMP*Comp(TM)
Passive mitigation
considered:
  • None
not considered:
  • Blast walls

5. Flammables: Alternative release

Some Risk Management Plan information is not provided in the available RMP data. You need to make an appointment at an EPA Reading Room In order to get access to details from the Off-Site Consequence Analysis (OCA) such as:

Instructions on how to make an EPA appointment can be found here.

Public OCA Chemical (in Unspecified process)
CBI claimed:
No
Model used:
PHAST
Passive mitigation
considered:
  • None
not considered:
  • Dikes
  • Fire wall
  • Blast walls
  • Enclosures
Active mitigation
considered:
  • None
not considered:
  • Sprinkler systems
  • Deluge systems
  • Water curtain
  • Excess flow valve

6. Five-year accident history

No Registered Accidents

7. Prevention: Program level 3

, Natural Gas Liquid Extraction (211112)
Prevention Program ID:
1000046130
Safety Review Date
May 1, 2014, since latest RMP submission
PHA Update Date
Nov. 18, 2010, since latest RMP submission
PHA Techniques
  • What if/Checklist
Hazards Identified
  • Fire
  • Explosion
  • Overpressurization
  • Corrosion
  • Overfilling
  • Contamination
  • Equipment failure
Process Controls
  • Vents
  • Relief Valves
  • Check Valves
  • Scrubbers
  • Flares
  • Manual Shutoffs
  • Automatic Shutoffs
  • Interlocks
  • Alarms
  • Emergency Air Supply
  • Emergency Power
  • Backup Pump
  • Grounding Equipment
  • Inhibitor Addition
  • Rupture Disks
  • Excess Flow Device
Mitigation Systems
  • Dikes
  • Enclosure
Monitoring Systems
  • Process Area
Changes since PHA
  • None
Training Type
  • Classrom
Competency Testing
  • Written Test
Procedure Review Date
May 6, 2014, since latest RMP submission
Training Review Date
May 1, 2014, since latest RMP submission
Maintenance Review Date
Sept. 23, 2013, since latest RMP submission
Maintenance Inspection Date
May 29, 2014, since latest RMP submission
Equipment Tested
Yes
Management of Change Most Recent Date
June 10, 2014
Management of Change Review Date
Sept. 1, 2013
Pre-startup Review Date
June 10, 2014
Compliance Audit Date
Oct. 3, 2012
Compliance Audit Change Completion Date
Oct. 3, 2012
Incident Investigation Date
July 16, 2013
Incident Invest. Change Completion Date
July 23, 2013
Participation Plan Review Date
Sept. 1, 2013
Hot Work Review Date
Sept. 1, 2013
Contractor Safety Review Date
Sept. 1, 2013, since latest RMP submission
Contractor Safety Eval. Date
April 23, 2014, since latest RMP submission

8. Prevention Program level 2

No Prevention Program level 2

9. Emergency response

Facility In Community Plan:
Yes
Facility Own Response Plan:
No
Specific Facility Response Plan:
Yes
Inform. Procedures in Response Plan:
No
Emergency Care in Response Plan:
Yes
Plan Review Date:
Response Training Date:
May 1, 2014
Local Response Agency:
Local Response Agency Phone:
(337) 439-9911
Subject To - OSHA EAP:
No
Subject To - OSHA HAZWOPER:
Yes
Subject To - CWA:
No
Subject To - RCRA:
Yes
Subject To - OPA:
No
Subject To - State EPCRA:
Yes
Subject To - Other:

Executive Summary

ACCIDENTAL RELEASE PREVENTION AND EMERGENCY RESPONSE POLICIES



The Gillis Gas Plant has a long-standing commitment to the safety of the neighboring

community as well as employees and contractors on plant property. Targa, operator of the Gillis

Gas Plant, is dedicated to safety and environmental stewardship, which are two of the company's

core values. Safety and protection of the environment are an integral part of Targa's operations

and corporate culture.



The Targa Gillis Gas Plant adheres to all Targa policies, which can be summarized as follows

with regard to safety and environmental stewardship:



- All Safety and Environmental incidents are preventable.

- The Goal is Zero A? Zero Significant Incidents. Period.

- All employees and contractors are responsible for their personal safety.



Targa Corporate policies are embodied in the numerous Safety, Health, and Environmental

Policies & Procedures which apply globally to Targa operations. At the Gillis Gas Plant, these

policies are outlined and implemented via the Gillis Gas Plant Safety, Health, and Environmental

(SHE) Manual. This manual is available to all employees, and all employees have been trained

in their specific responsibilities for Safety, Health, and Environmental compliance. In addition,

the Gillis Gas Plant complies with the Process Safety Management (PSM) Program

requirements, which are managed and implemented via the Natural Gas and Gas Products

(NG&GP) Process Safety Management Program manual. This manual is also available to all

employees, and all employees receive specific training on Process Safety Management and their

role in the program. The Gillis Gas Plant also maintains an Incident Response Plan that details

the complete Emergency Response program for this site.



The Gillis Gas Plant's dedication to safety is demonstrated in many ways. The Plant and Targa

have a safety record that is consistently among the very best in the energy industr
y in the United

States. To help ensure the safety of Targa operations, the company invests significant resources

in accident prevention. Accident prevention includes designing safe plants and operating

facilities, conducting and providing safety training for employees and contractors, and

developing and implementing safe work practices and procedures for the operation and

maintenance of plants, processes, and operations facilities. Targa's policies and dedication to

safety and environmental stewardship help to prevent accidental releases. If, despite our best

attempts to prevent such incidents, a release should occur, trained personnel will respond to,

control, and contain the release in accordance with the plant's Incident Response Plan.



This document has been prepared in accordance with the EPA's Risk Management Program

(RMP) regulations (40 CFR Part 68), which were promulgated in the Federal Register on

June 20, 1996, and last revised on April 9, 2004.



DESCRIPTION OF THE FACILITY AND THE REGULATED SUBSTANCES HANDLED



The Gillis Gas Plant, located in Calcasieu Parish, Louisiana, is owned and operated by Targa

Resources, Inc. The Gillis Gas Plant is a natural gas processing plant that receives raw natural

gas and natural gas liquid streams by pipeline. The site consists of inlet gas separation,

dehydration, cryogenic gas processing (recovery of natural gas liquids), fractionation, product

storage and loading equipment. Products are transported from the facility via pipeline and truck.



In accordance with the EPA's Risk Management Program (RMP) regulations (40 CFR Part 68),

the Gillis Gas Plant's inventory of chemicals was evaluated to determine if any regulated

flammable or toxic substances were on the plant site in quantities above the threshold quantities.

[Note: The term "threshold quantity" is the quantity above which the EPA has decided that the

substance will be regulated.] Our evaluation determined that
there are listed flammable

substances handled by the plant in quantities above the substance's threshold quantity. There are no toxic substances above the threshold quantity at the plant.



GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM AND CHEMICAL-

SPECIFIC PREVENTION STEPS



The Gillis Gas Plant adheres to the policies and procedures provided in the Process Safety

Management (PSM) Program. These policies and procedures include and embrace the

requirements of 29 CFR 1910.119 and 40 CFR Part 68.



The following is a general overview of the main elements of the Risk Management Program that

are currently in operation at the Gillis Gas Plant. The Gillis Gas Plant has aligned and integrated

its safety management programs at a high level with the Occupational Safety & Health

Administration's (OSHA) Process Safety Management (PSM) program regulations for

consistency and effectiveness. As a result, this overview describes the safety management

system that is in place for each of the safety management program elements, which also make up

the Risk Management Program.



Employee Participation



All employees (and contractors) at the Gillis Gas Plant are involved and participate in all facets

of Process Safety Management (PSM) and accident prevention. Examples of Employee

Participation include, among other things:



- Implementing Targa policies and procedures concerning employee and public safety and

environmental protection,

- Preparing and/or updating technical documents such as operating and maintenance

procedures,

- Working in accordance with standard operating procedures and safe work practices,

- Participating in safety meetings,

- Participating in training,

- Participating in the Management of Change (MOC) process,

- Participating in the Process Safety Management (PSM) audit process or a Process

Hazards Analysis (PHA) team.



Employees have access to, are aware of, and are trained about the existence and location of all of


the information that is included in the facility's Risk Management Program. More specific ways

that employees can be involved in the Risk Management Program are documented in an

Employee Participation Plan that is maintained at the plant.



In addition, employees and management have a number of initiatives in place that are designed

to improve safety at the plant. These initiatives are focused on both the plant processes and

general worker safety (including slips, trips, and falls), and even off-the-job safety.



Process Hazard Analysis (PHA)



The Gillis Gas Plant has a comprehensive program to help ensure that hazards associated with

the plant's operations and processes are identified and minimized. This is a systematic

procedure in which each part of the process is systematically examined to identify all of the

potential hazards associated with the process, and to ensure that appropriate recommendations

are developed and implemented to eliminate or control the potential hazards.



The Process Hazards Analysis procedure utilized at the Gillis Gas Plant is carried out by a team

of functional experts from engineering, operations, maintenance, and safety, who work with a

PHA Facilitator to identify and evaluate all of the potential hazards that could possibly result in a

release of a regulated substance. The team also evaluates potential mitigation measures and

accident prevention measures for each potential process hazard at the facility. The final part of

the procedure requires the team to make specific suggestions for management consideration to

address or mitigate each identified hazard.



The PHA team's findings and suggestions are provided to plant management for further

evaluation and resolution. All approved mitigation options are then tracked as part of the process

until they are completed. The final resolution of each finding is documented and retained.



To help ensure that the process controls and/or process
hazards are continuously evaluated and

maintained in a safe condition, the plant periodically updates and revalidates the Process Hazard

Analysis. These periodic reviews are conducted every 5 years and will continue at this

frequency as long as the plant is in operation. The results and findings from these updates are

documented and retained. Once again, the team findings are forwarded to management for

consideration, and final resolution of the findings is documented and retained.



Process Safety Information



The Gillis Gas Plant maintains a variety of technical data that is used to ensure safe operation of

the processes. These data and documents include written data and engineering drawings on the

design of the facility, the chemistry of the process and associated hazards, safe operating limits

for key process parameters, specific chemical inventories, and equipment design

basis/configuration information. Specific personnel within the gas plant are assigned

responsibility for maintaining up-to-date process safety information.



Safety data are maintained for all chemicals that are used, handled, or produced at the facility.

These data include permissible exposure limits, physical data, reactivity and corrosive

information, thermal and chemical stability, toxicity data (if applicable), personal protective

equipment, and measures to be taken in the event of physical contact or airborne exposure to a

chemical. This information is maintained in Material Safety Data Sheets (MSDS), as part of the

Hazard Communication Program at the plant.



For specific process areas, the Plant has documented the safe operating limits for specific process

parameters (e.g., temperature, pressure, level, etc.). The Plant ensures that the process is

maintained within these limits using process controls and monitoring instruments, highly trained

personnel, and protective instrument systems such as automatic shutdown systems.



The Plant a
lso maintains numerous technical documents that provide information about the

design and construction of process equipment. This information includes design flow rates, fluid

properties, pressures and temperatures that were the basis of the sizing of the different

subsystems or individual pieces of equipment. The information on the process design also

includes the materials of construction, design pressure and temperature ratings, and electrical

ratings of equipment. The engineering data maintained at the plant includes a Plot Plan, Piping

and Instrumentation Diagrams (P&IDs), Process Flow Diagrams (PFDs), Electrical Area

Classification drawings, Safety Analysis and Function Evaluation (SAFE) Charts, Cause and

Effect (C&E) Charts, and equipment specification/data sheets. This information, in combination

with written procedures and trained personnel, provides a basis for establishing inspection and

maintenance activities, as well as for evaluating proposed process and facility changes to ensure

that safety features in the process are not compromised.



Operating Procedures



The Gillis Gas Plant developed and maintains written operating procedures that provide plant

operators with a clear understanding of the tasks involved in the safe operation of the facility.

Operating procedures that address various modes of process operations are maintained, such as

(1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5)

normal shutdown, and (6) initial startup of a new process. These procedures provide the basis

for consistent training of new operators, and they provide good reference materials for

experienced operators. These procedures are periodically reviewed and certified as current and

accurate. Whenever a process modification is made, the procedures are revised as appropriate to

cover the modification. The procedures are kept current by revising them as necessary to reflect

changes
made through the management of change process.



These procedures are used in employee training, and are readily available to employees to use as

necessary to safely perform their job tasks.



Training



The Gillis Gas Plant employs a comprehensive training program for all employees at the plant.

New employees receive job-specific basic training in gas plant operations. All operating and

maintenance personnel receive facility-specific process overview training. Each employee

receives training on, among other things, (1) an overview of the process, (2) safety and health

hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5)

applicable safe work practices to ensure that they can perform their jobs in a safe manner. They

are thereby trained in the specific knowledge, skills, and procedures needed to safely conduct

their work. In addition, each operator receives facility-specific training on how to operate the

plant, including detailed training on the operating procedures, including startup, shutdown,

normal operations, temporary operations, and emergency operations. As part of this training, an

operator in training is paired with an experienced operator to learn process-specific duties and

tasks. After operators demonstrate (through tests and skills demonstration) the knowledge to

perform the duties and tasks in a safe manner on their own, only then can they work

independently. In addition, all operators periodically receive refresher training to ensure that

their skills and knowledge are maintained at a high level. This refresher training is provided as

often as necessary, but no less than every 3 years. All of this training is documented for each

operator, including the means used to verify that the operator understood the training.



Contractors



The Gillis Gas Plant uses contractors to perform many project-specific activities and supplement

the plant workforce during periods of incre
ased maintenance or construction periods. For those

contractors who work on or near process equipment, the plant has procedures in place, that when

followed, ensure that these contractors:



- Perform their work in a safe manner,

- Have the appropriate knowledge and skills to work safely around the process,

- Are aware of the hazards in the workplace,

- Understand what they should do in the event of an incident,

- Understand and follow site safety rules, and

- Inform gas plant personnel of any hazards that their work brings and/or that they find

during their work.



The Gillis Gas Plant has developed and implemented safe work practices and procedures to

control the entrance, presence, and exit of contract employers and employees in covered process

areas.



Each contract employee is provided with site-specific training on the hazards that may exist at

that plant. Each contract employee is provided an orientation on the known potential fire,

explosion, or release hazards related to the contractor's work and the process, as well as the

applicable provisions of the incident response plan.



Contractor safety programs and safety performance are evaluated and become part of Targa's

contractor selection process. Targa personnel periodically monitor contractor safety programs

and performance records.



Management of Change (MOC)



Throughout the life of any operating facility, changes will often be necessary A? for example, to

meet changing circumstances, to make needed improvements, or to alter the technology of the

process. The Gillis Gas Plant has a comprehensive system in place to manage and document any

such changes to the plant's processes. This system requires that changes to items such as process

equipment, chemicals, technology (including process operating conditions), procedures, or other

changes be properly reviewed and authorized by a number of people with different functional

expertise before being implemented. T
his system of managing facility modifications is called

Management of Change (MOC). This system consists of a set of written procedures that are

used to identify and eliminate hazards associated with a change to the facility's processes. MOC

ensures that facility modifications are formally reviewed and approved before being

implemented. Changes are reviewed to (1) ensure that adequate controls are in place to manage

any new hazards and (2) verify that existing controls have not been negatively affected by the

change. A part of the MOC process ensures that any chemical hazard information, process

operating limits, equipment information, and/or procedures are updated as appropriate to

incorporate the effects of the modification. A critical piece of the MOC process ensures that

operating and maintenance personnel are provided any necessary training regarding the process

modification.



Pre-Startup Safety Reviews (PSSRs)



The Gillis Gas Plant conducts a Pre-Startup Safety Review (PSSR) for any modification that

requires a change in the process safety information. The purpose of the PSSR is to ensure before

startup of the modified process or unit that the modification was completed in accordance with

design specifications. The PSSR is also intended to ensure that safety features, procedures,

personnel, and equipment are properly prepared for startup before the modified equipment is put

in service. Another key purpose of the PSSRs is to ensure that all personnel have been trained

on the modification, including any revisions to the operating procedures or to the safety systems

and controls. This review provides one additional check to make sure that all personnel and

supporting systems are operationally ready to operate the newly-modified process or equipment.

The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field

verification of the construction, and serves a quality assurance f
unction by requiring verification

that accident prevention, Process Safety Management Program, and Risk Management Program

requirements are properly implemented.



Mechanical Integrity



The Gillis Gas Plant has well-established practices and procedures to maintain process

equipment in a safe operating condition. This mechanical integrity program includes pressure

vessels, piping systems, relief and vent systems, controls, pumps, compressors, and emergency

shutdown systems, among other items. The basic aspects of this program include:



(1) conducting training,

(2) developing written procedures,

(3) performing inspections and tests,

(4) correcting identified deficiencies, and

(5) applying quality assurance measures.



In combination, these activities form a system that maintains the mechanical integrity of the

process.



As stated above (under Training), maintenance personnel receive training on (1) an overview of

the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) incident

response plans, and (5) applicable safe work practices to help ensure that they can perform their

jobs in a safe manner. In addition to being used in training, written procedures are intended to

ensure that maintenance work is performed in a consistent manner.



Inspections and tests are performed to help ensure that equipment functions as intended and to

verify that equipment is within acceptable limits (e.g., adequate wall thickness for pressure

vessels). If a deficiency is identified, employees will correct the deficiency before placing the

equipment back into service or a management of change team will review the use of the

equipment and determine what actions are necessary to ensure the safe operation of the

equipment.



An integral part of the mechanical integrity program is quality assurance. Quality assurance

measures are incorporated into equipment purchases and repairs. This helps ensure that new

equi
pment is suitable for its intended use and that the proper materials and spare parts are used

when repairs are made.



Safe Work Practices



As part of the design and startup of the facility, the Gillis Gas Plant developed safe work

practices designed to ensure worker and process safety and these safe work practices are

followed to ensure that operations and maintenance activities are performed safely. Examples of

safe work practices include:



1. control of the entry/presence/exit of support personnel,

2. a lockout/tagout procedure to ensure isolation of energy sources for equipment undergoing

maintenance,

3. a procedure for the safe removal of hazardous substances before process piping or equipment

is opened,

4. a permit and procedure to control spark-producing activities (i.e., hot work permit),

5. a permit and procedure to ensure that adequate precautions are in place before entry into a

confined space,

6. use of appropriate site-specific and job-specific personal protective equipment, and

7. a methodical procedure termed a Job Safety Analysis (JSA) for ensuring that the proper

precautions are in place prior to undertaking any non-routine tasks.



These safe work practices and procedures, along with training or affected personnel, form a

system designed to ensure that operations and maintenance activities are performed safely at all

times.



Incident Investigation



The Gillis Gas Plant promptly investigates all incidents that resulted in, or reasonably could have

resulted in, a fire or explosion, gas release, major property damage, environmental loss, or

personal injury. The goal of each investigation is to determine the facts and underlying cause(s)

of the incident to develop corrective actions and implement steps to prevent a recurrence of the

incident and prevent similar incidents. The investigation team documents its findings, develops

recommendations to prevent similar incidents, and forwards these results to ma
nagement for

further action. Corrective actions taken in response to the investigation team's findings and

recommendations are tracked until they are fully implemented. The final resolution of each

finding or recommendation is documented, and the investigation results are reviewed with all

employees (including contractors) who could be affected. Incident investigation reports are

retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA

revalidations.



Compliance Audits



To ensure that the Risk Management Program is functioning properly, the Gillis Gas Plant

periodically conducts audits to verify that the policies, procedures and practices required by the

Risk Management Program are being implemented properly and fully, to evaluate the

effectiveness of the program, and to develop ideas for improving the program. These audits are

independent, site-specific, and methodical. Compliance audits are conducted every 3 years. The

findings of the audit are forwarded by the audit team to plant management for priority resolution.

Corrective actions taken in response to the audit team's findings are tracked until they are

complete. The final resolution of each finding is documented, and the two most recent audits

reports are retained for future review.



CHEMICAL-SPECIFIC ACCIDENT PREVENTION STEPS



The processes at the Gillis Gas Plant involve regulated substances that are controlled to ensure

the continuous safe operation of the plant. The following is a description of existing safety

features in place to prevent accidental releases of regulated substances at the facility.



Universal Prevention Activities



The Risk Management Program summarized above is applied throughout the Gillis Gas Plant.

Collectively, these prevention program activities work to prevent potential accident scenarios

that could be caused by equipment failures or human errors.



Specialized Safety Features



The Gil
lis Gas Plant has safety features throughout the facility to:



- Contain/control a release,

- Quickly detect a release, and

- Reduce the consequences of a release in the unlikely event of an accidental release.



The following types of safety features are used in the plant's processes:



Release Detection, including:



Hydrocarbon gas detectors with alarms



Release Containment/Control, including:



1. Process relief valves that discharge to a flare system to contain and incinerate releases;

2. Valves to permit isolation of the process (manual or automated);

3. Automated shutdown systems for specific process parameters (e.g., high pressure or

temperature);

4. Curbing or diking to contain liquid releases;

5. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process

control system); and

6. Pressure safety relief devices.



Release Mitigation, including:



1. Fire detection, suppression, and extinguishing systems, including portable fire

extinguishers all around the plant, and a fire water system with monitors located

throughout the plant;

2. Personnel trained as First Responders;

3. Emergency Shut-Down (ESD) System to immediately isolate and shut down the process

to minimize the release;

4. Immediate access to and communication with local emergency response organization,

including the fire department, police, and other local emergency response organizations;

5. Incident Response Plan, which is a detailed emergency action plan that includes detailed

procedures for responding to accidental releases; and

6. Incident Response Drills to simulate an accidental release to practice actual

implementation of the incident Response Plan and to coordinate response activities with

the local emergency response organizations mentioned above.



THE FIVE-YEAR ACCIDENT HISTORY



No deaths, injuries, or significant property damage on site, or known off-site deaths, injuries,

evacuations, sheltering in place, proper
ty damage, or environmental damage have resulted from

any activities or incidents at the Gillis Gas Plant for the past five years.



THE EMERGENCY RESPONSE PROGRAM



The Gillis Gas Plant maintains a written Incident Response Plan, which is in place to protect

public safety and worker safety (both employees and contractors), as well as the environment,

and to minimize any effects in the unlikely event of an emergency. The plan consists of detailed

procedures for responding to accidental releases, as well as procedures for responding to fires

that might occur in the unlikely event of a release of a flammable substance. These response

procedures address the following aspects of emergency response, and more:



- Proper first aid and treatment for any exposures;

- Evacuation plans which include provisions for accounting for all personnel (employees,

contractors, and visitors) after an evacuation;

- Notification to appropriate emergency response agencies; and

- Post-incident cleanup and decontamination requirements.



The Plant has procedures that address maintenance, inspection, and testing of incident response

equipment intended to ensure that the equipment will work as designed in the event of an

emergency. Training is conducted to ensure the proper use of emergency response equipment,

such as fire-fighting equipment. Employees are assigned specific roles that they would fill in the

event of an emergency, and all employees received specific training to enable them to fulfill their

roles in an emergency. The incident response plan is updated when necessary based on legal

requirements and modifications made to plant processes.



The overall incident response program for the Gillis Gas Plant is coordinated with the Calcasieu Office of Emergency Preparedness. This coordination includes periodic meetings of Gillis Gas Plant

personnel with the Calcasieu Office of Emergency Preparedness to review incident response plans and

facili
tate communications and planning. The Gillis Gas Plant has around-the-clock

communications capability with the Calcasieu Office of Emergency Preparedness and emergency response

organizations (e.g., fire department). This provides a method for notifying the public in the

event of an incident, if necessary, as well as facilitation quick response to an incident. In

addition to periodic meetings with Calcasieu Office of Emergency Preparedness, the Gillis Gas Plant

conducts periodic emergency response drills that involve the Calcasieu Office of Emergency Preparedness

and emergency response organizations.



PLANNED CHANGES TO IMPROVE SAFETY



Rather than implement improvements in an ad hoc manner, the Gillis Gas Plant has processes in

place that are employed to improve safety on a continuing and ongoing bases, to ensure that the

safety programs are continuously improved. These processes include the following:



- Safety teams.

- Incident response drills involving off-site emergency responders.

- Process Hazards Analysis revalidations.

- Management of change.

- Mechanical Integrity & Quality Assurance.

- Compliance audits.

- Continued focus on the "The Goal is Zero" for injuries and incidents.



SAFETY IS A JOB REQUIREMENT FOR ALL EMPLOYEES AND CONTRACTORS.



AT TARGA, OUR WORK IS NEVER SO URGENT OR IMPORTANT THAT WE CANNOT

TAKE THE TIME TO DO IT SAFELY.