ENVIRONMENTAL OVERVIEW AND OUR COMMITMENT
At Targa, we are committed to protecting our employees, our contractors, and the people living in the communities in which we work and operate from risks associated with our operations. Wherever we operate, we strive to conduct our business with attention to the environment and to manage risks to enable sustainable business growth. We endeavor to reduce and eliminate injuries, occupational illnesses, and incidents of environmental harm arising from our activities. We take our commitment to fulfill the requirements of all federal, state, and local agencies very seriously. We seek to be leaders in our industry by working directly with government agencies, industry groups, and engineering firms. As a member of the community, we aim to be a good corporate citizen. We value our relations with our neighbors and the government agencies who regulate our operations.
To support our efforts in this area, we have implemented an environmental, safety and health ES&H framework of policies, practices, systems, and controls that includes automated permit compliance tracking, systems development, compliance audits, and training. In addition, we work with federal, state, and local agencies during lawmaking and rulemaking, technology review, and benchmarking.
Targa’s approach to ES&H is articulated in our Environmental, Safety and Health Statement. We review our key ES&H metrics and performance quarterly with our Board of Directors. We strive to operate safely, reliably and in a way that avoids, minimizes, and mitigates our environmental impacts.
At Targa, we routinely engage with regulatory agencies, either alone or through our industry associations, on both policy development and education. We work hard to keep an open and transparent relationship with our federal, state, and local agencies. For example, Targa is a member company of the EPA Natural Gas STAR Program, which is a voluntary partnership between the EPA and oil and natural gas companies to adopt cost effective technologies and practices to reduce methane emissions.
Recently, Targa was honored by the North Dakota Petroleum Council with the Excellence in Environmental Stewardship Award for its work to advance microbiological treatment of soils contaminated by crude oil and hydrocarbon condensate. Our pilot program is making great strides in proving bioremediation as a viable alternative to traditional landfill disposal of oil and gas wastes and a beneficial reuse of a natural resource.
Managing and Reducing Emissions
We conduct the following activities in each of our business segments to manage our air permitting and compliance program:
- Develop and maintain a permit requirements list in our compliance tracking system, along with required actions, deadlines, and designated responsible persons; and
- Provide regular training and re-training for operations, engineering, and maintenance staffs’ understanding of permit requirements.
- Identify, record, and maintain a list of stationary air emission sources, including insignificant sources and sources of fugitive emissions;
- Quantify facility annual emissions per federal, state, provincial, or local requirements and document the basis of the quantification and estimation;
- Quantify emissions when changes and/or modifications occur or are contemplated to occur at a facility to determine if the facility permitting status is affected (e.g., exempt, minor, synthetic minor, or major under Title V);
Emissions at our facilities generally result from natural gas combustion from operating natural gas compressor engines and process heaters and from methane and carbon dioxide that escape operating equipment, flaring, venting, and other processes common to natural gas systems. Under applicable greenhouse gas laws, reporting is required for facilities at or above the 25,000 metric tons of carbon dioxide equivalents (CO2e) per year threshold set by the EPA.
With the growth in domestic supply fundamentals, Targa has continued to invest in energy infrastructure to meet customer needs. As a result, Targa's gathering and processing and fractionation system volumes have significantly increased over the measurement period referenced below.
While product sales have increased at our facilities as a result of Targa's increased operational scale, our emissions
intensity remains relatively constant while we have been undergoing unprecedented growth.
Where feasible, Targa seeks to reduce these emissions by:
- Installing lower emitting equipment during facility expansions;
- Reducing emissions from product transfer operations through the use of vapor balanced loading/unloading procedures;
- Utilizing leak certified tank trucks that meet or exceed EPA standards;
- Recovering products that would otherwise be flared or lost to atmosphere by using vapor recovery units;
- Maintaining properly tuned and efficient compressor engines through preventative maintenance and emission testing; and
- Evaluating and expanding gathering system capacity and flexibility to reduce field gas flaring.
At Targa, we work to minimize and accurately and timely report releases and emission events that are reportable to a state or federal agency.
Permian and Williston Basin Flaring
Significant drilling activity in recent years in the Permian and Williston Basins has caused natural gas production to exceed the capacity of existing natural gas gathering and processing infrastructure, which results in the flaring of natural gas by producers.
Over the past five years, Targa has increased its natural gas gathering and processing infrastructure through the construction of additional processing plants, compression capacity, and gathering pipelines. This increase in infrastructure increases gas capture and reduces producer flaring of natural gas in the Permian and Williston Basin. We continue to work proactively with crude oil and natural gas producers in this area to forecast locations where infrastructure may support increased natural gas capture and reduce flaring. As production grows, these relationships remain important to measurable reductions in flaring for the basins.
Targa implements leak detection and repair programs for our pipelines, gas plants, compressor stations, and fractionation and storage facilities. Some of these programs may meet an applicable regulatory requirement while others are voluntary. These programs help identify unexpected leaks which benefits both the environment as well as ensuring no unwanted loss of valuable natural resources. Leak detection methods are broadly classified into two categories: external leak detection methods (i.e. aerial patrol and on-site inspection) and internal leak detection methods (i.e. pressure flow monitoring and computational pipeline monitoring).
Facilities subject to these leak detection and repair inspections vary depending on facility type. Surveys may be conducted monthly, quarterly, or annually. If we identify a leak during our inspections, we conduct repairs and then confirm the repair addressed the leak, if needed.
Types of leak detection inspections at Targa include:
- Field inspections of pipelines via walking, ATV, or truck;
- Aerial leak surveys;
- Plant and compressor station leak detection and repair programs; and
- Optical Gas Imaging (OGI) Programs including dedicated OGI personnel.
Spill Prevention and Response
Targa implements spill prevention, emergency preparedness, and spill response programs to minimize impact to the environment. These programs focus on prevention and preparedness in order to:
- Prevent – Implementation of Spill Prevention, Control, and Countermeasures (SPCC) and Facility Response plans at our assets;
- Prepare – Train staff and perform drills to effectively and efficiently respond if a spill were to occur; and
- Respond – Maintain adequate supply of spill response equipment and procure spill response contractors to efficiently control a spill to minimize impact to the environment.
If a spill does occur, Targa utilizes a cross-functional team that focuses first on safety and then on environmental protection and regulatory compliance.
Protecting Resources During Construction
Targa strives to minimize impacts to the environment during the construction and operation of our assets. The assessment of potential environmental effects during a new project involves a tiered conservation approach of avoidance, minimization, and mitigation. Prior to beginning a project, we develop plans and procedures relating to surveying, construction, impact avoidance, mitigation, revegetation, and operations. To evaluate a proposed route on a new pipeline project, we conduct civil, cultural, and environmental surveys. Environmental and cultural surveys are completed for wetlands, streams, protected species, and cultural resources before construction projects begin. The purpose of the surveys is to gather information about the following:
- Threatened and Endangered Species;
- Cultural resources;
- Land use; and
- Other important biodiversity considerations.
Our environmental specialists consult with applicable environmental agencies and conduct extensive studies to identify environmental resources and implement measures to reroute and avoid, or minimize impacts.
During construction, potential effects on resources may be minimized by using different crossing methods that do not disturb the resources, such as hydraulic directional drilling or boring beneath the resources. Industry “best management practices” are also implemented. For example, in active construction across stream banks, sediment barriers and storm water filtration devices are installed and maintained regularly to eliminate erosion from storm water runoff. We also provide required inspection for stream bank stabilization and restoration in accordance with applicable regulations, which increases restoration efficiency and reduces soil exposure to erosion post construction.
Following construction, we work to restore the right-of-way, including, where possible, seeding the property to landowner and Targa agreed-upon specifications with native grass seed obtained from local soil conservation offices. We also provide inspections of the right-of-way, where possible, to ensure effectiveness of the native grass seed growth. Being good stewards of the land requires extra attention in areas impacted by construction. As we continue to execute on our capital-growth strategies, restoration of right of way will remain a key focus.
Targa participates in the Lesser Prairie Chicken Range-wide Conservation Plan and American Burying Beetle’s Industry Conservation Plan. These species and habitat conservation measures focus on the restoration of species habitat and population growth.
We are involved in a number of projects designed to enhance biodiversity within our operating areas. We have made long-term commitments to manage biodiversity and participate in conservation education and community outreach initiatives.
We strive to be energy efficient and have implemented several energy management initiatives that reduce our energy consumption. For example, Targa has installed solar panel powered metering stations (> 10,000 sites) to reduce load on the electrical grid and reduce combustion emissions. We also employ electrical load-shedding techniques on a variety of our assets and continue exploring ways to expand this practice and other methods to improve energy efficiencies. We also focus efforts on waste minimization programs such as soil bioremediation for reuse, used oil and metal recycling.