Liquid Pipeline Integrity Management
Williams is providing the following summary of its Midstream Liquid Pipeline Integrity Management Plan (IMP) that identifies supplemental safety procedures in high consequence areas. High consequence areas are those locations where a pipeline spill might have significant adverse impacts to areas of population, the environment, and/or commercial navigation.
The goal of Williams Midstream 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 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 in pipeline integrity.
The IMP outlines processes that are used to assess risks and manage risks associated with operating the hazardous liquid pipeline system, in order to reduce both the number of incidents and the adverse effects of incidents. This program is intended to meet the requirements of integrity management programs required under Title 49 CFR 195.452 of the federal pipeline safety regulations and 30452 State of Louisiana.
The Williams Midstream Liquid Pipeline IMP encompasses the following hazardous liquid pipeline systems and system operator:
Williams Energy, L.L.C
- Discovery 18″/14″/10″ NGL Pipeline
Williams Oil Gathering, L.L.C
- Banjo 16′
- Nansen 12′
- Boomvang 16′
- Gunnison 18′
- Mountaineer 18’ (MC684 to MP 313)
- Mountaineer 20′
- Blind Faith 14″/16″
- Perdido Norte 18”
Williams Field Services Company, L.L.C.
- PGX 6″ and 8″ NGL Pipeline
- Willow Creek 8” NGL Pipeline
- Willow Creek 14” NGL Pipeline to OPPL
Williams Field Services-Gulf Coast Company
- Devils Tower 14’ (MC773 to MC684)
- Canyon Station 4’ Condensate
Mid-Continent Fraction and Storage, L.L.C
- Conway to Mitchell 10″ Propane Pipeline
- Conway to Mitchell 16″ EP Pipeline
- Conway West Product Storage Pipelines
- Conway Underground East Product Storage Pipelines
- Mitchell Product Storage Pipelines
The following guiding principals were utilized in the development of the Williams Midstream Liquid 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 this 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 facility is only part of the complete system that allows Williams Midstream to reduce both the number of incidents and the adverse effects of errors and incidents. The total system also includes Williams Midstream employees and third party resources who 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. The IMP will be frequently evaluated and modified 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. Williams Midstream 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; or 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, Williams Midstream 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 Williams Midstream 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 Williams Midstream 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. Williams Midstream will periodically gather additional information and system operating experience. This information is factored into the understanding of system risks. As the significance and relevance of this additional information to risk is understood, integrity plan is adjusted accordingly. This may result in changes to inspection methods or frequency, or additional modifications to the pipeline system in response to the data. As changes are made, different pipelines within Williams Midstream will be at different places with regard to the goal of incident-free operation. Williams Midstream will establish specific goals and measures to monitor the improvements in integrity and to assess the need for additional changes.
7. New technology must be evaluated and utilized, as appropriate.
Williams Midstream 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 Williams Midstream to apply the most appropriate technologies or techniques to a specific risk to best address potential impacts.
8. Pipeline system integrity and integrity management programs must be evaluated on a regular basis.
The Office of Pipeline Safety provides a periodic review of the integrity management program for Williams Midstream through its enforcement personnel. Williams Midstream will periodically perform internal reviews to ensure the effectiveness of the integrity management program in achieving the program’s goals. Performance measures will be utilized to both judge program effectiveness and to identify opportunities for improvement or additional emphasis.