Field Services Integrity Management
Williams Field Services (WFS) is one of the operating companies of Williams Midstream Gas and Liquids. The WFS Integrity Management Plan (IMP) applies to all of the Williams Midstream Gas and Liquids gas transmission pipelines.
WFS is providing the following summary of its Gas Transmission Pipeline Integrity Management Plan (IMP) that identifies supplemental safety procedures for its gas transmission pipelines.
The goal of WFS is to operate the pipeline system in such a way that there are no adverse effects on employees, the environment, the public or our customers. The goal is defined by the Williams philosophy of Operational Excellence – zero injuries, zero accidents, zero releases.
The IMP provides a means to improve the safety of pipeline systems and to allocate resources effectively to:
- Identify and analyze actual and potential precursor events that can result in pipeline incidents.
- Provide a comprehensive and integrated means for examining and comparing the spectrum of risks and risk reduction activities available.
- Provide a structured and comprehensive means for selecting and implementing risk reduction activities.
- Ensure the utilization of appropriately trained and qualified company and third-party personnel for risk management and pipeline integrity assurance.
- Establish and track system performance with the goals of continued improvement and establishment of best practices for pipeline integrity.
On December 17, 2003, the United States Department of Transportation (DOT) adopted the final rule on Pipeline Integrity Management in High Consequence Areas (Subpart O, containing parts 192.901 through 192.521 and Appendix A and E). This Integrity Management Rule (“the rule”) specifies regulations to assess, evaluate, repair, and validate the integrity of gas transmission lines that, in the event of a leak or failure, could affect high consequence areas (HCAs).
Application
The WFS Gas Pipeline IMP encompasses the following gas transmission pipelines:
Williams Energy , L.L.C
- Discovery 30”
- Discovery 20” (40E)
- Discovery 12” (40E)
- LaRose 20”
- LaRose 16”
Williams Field Services Company
- LaCosa Discharge 16”
- LaCosa Suction 16”
- Chaco Suction 20”
Black Marlin Pipeline Company
- Black Marlin 16”
Mobile Bay Producer Services
- Mobile Bay Discharge 20”
Guiding Principles
In accordance with the requirements of the rule, this document represents WFS’s written Integrity Management Plan (IMP) for Gas Transmission Pipelines and provides guidelines for continual assessment of all pipeline segments that could adversely affect HCAs, as defined in the rule. WFS plans to achieve integrity assessments (integrity tests) of its transmission pipelines and facilities through internal inspection, pressure testing, or other equally effective means approved by sound engineering practices and authorized by the DOT’s Office of Pipeline Safety (OPS) or, if necessary, other governing agencies.
Williams used the following guiding principals in developing the WFS Gas Pipeline IMP:
1. Integrity must be built into pipeline systems from initial planning, design and construction.
Integrity management of a pipeline starts with the sound design and construction of the pipeline. As these standards and guidelines are applied to the design of a pipeline, the designer must consider the area the pipeline traverses and the possible impacts that the pipeline may have on that area and the people that reside in the vicinity. New construction is not a subject of this program, but the design specifications and as-built condition of the pipeline provide important baseline information for the IMP.
2. System integrity must be built on qualified people, using defined processes to operate maintained facilities.
The integrity of the physical pipeline or related facility is only part of the complete system that allows WFS to reduce both the number of incidents and the adverse effects of errors and incidents. The total system also includes WFS employees and third party resources who may operate the facility and use the work processes.
3. An integrity management program must be flexible.
The IMP is customized to support the unique conditions of the pipeline systems. Williams will frequently evaluate and modify the IMP to accommodate changes in the pipeline design and operation, changes in the environment in which the system operates, new operating data, and other integrity-related information. Periodic evaluation is required to ensure the program takes appropriate advantage of improved technology and that the program remains integrated with the Williams business practices and effectively supports the integrity goals. WFS has multiple options available to address risks:
- Components of the facility or system can be changed
- Additional training can be provided to the people that operate the system
- Processes or procedures can be modified
- A combination of actions can be used that will have the greatest impact on managing and reducing risk.
4. The integration of information must be a key component for managing system integrity.
A key element of the IMP is the integration of all available information in the decision making process. Information that can impact an operator’s understanding of the important risks to a pipeline system comes from a variety of sources. By integrating all of the available information, WFS can determine where the risks of an incident are the greatest and make prudent decisions to reduce these risks.
5. Preparing for and conducting a risk assessment must be a key element in managing pipeline system integrity.
Risk assessment is an analytical process through which WFS determines the types of adverse events or conditions which might impact pipeline integrity, the likelihood that those events or conditions will lead to a loss of integrity, and the nature and severity of the consequences that might occur following a failure. This analytical process involves the integration and analysis of design, construction, operating, maintenance, testing, and other information about a pipeline system. Risk assessments can have varying scopes, varying levels of detail, and use different methods. However, the ultimate goal of assessing risks is to identify and prioritize the most significant risks so that WFS can make informed decisions about these issues.
6. Assessing risks to pipeline integrity must be a continuous process.
Analyzing for risks in a pipeline system is an iterative process. WFS will periodically gather additional information and system operating experience. WFS factors this information into the understanding of system risks. As WFS understands the significance and relevance of this additional information to risk, WFS adjusts its integrity plan accordingly. This adjustment may result in changes to inspection methods or frequency, or additional modifications to the pipeline system in response to the data.
7. WFS evaluates and utilizes new technology, as appropriate.
WFS will periodically assess the capabilities of new technologies and techniques that may provide improved understanding about the pipeline’s condition or provide new opportunities to reduce risk. Knowledge about what is available and effective will allow WFS to apply the most appropriate technologies or techniques to a specific risk to best address potential impacts.
8. WFS evaluates pipeline system integrity and integrity management programs on a regular basis.
The Office of Pipeline Safety provides a periodic review of the integrity management program for WFS through its enforcement personnel. WFS will periodically perform internal reviews to ensure the effectiveness of the integrity management program in achieving the program’s goals. WFS utilizes performance measures to both judge program effectiveness and to identify opportunities for improvement or additional emphasis.
