The Integrity Management Plan (IMP)
Williams Pipeline Integrity Management
Williams is providing the following summary of our Pipeline Integrity Management Plan (IMP) that identifies additional safety procedures that we implement on liquid and gas transmission pipelines in high consequence areas. High consequence areas are those locations where a pipeline spill might have significant adverse impacts:
- Gas transmission pipelines: areas of population
- Liquid transmission pipelines: areas of population, the environment, and/or commercial navigation
Our goal 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 of improving the safety of pipeline systems and allocating resources effectively to accomplish each of the following:
- 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 company uses 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
- Develop best practices in pipeline integrity
The IMP outlines processes that Williams uses to assess 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 and 192 Subpart O of the federal pipeline safety regulations and state pipeline safety regulations in Louisiana, New York, and Texas.
The IMPs provide guidance in completing the following required activities:
- Identifying all segments with high consequence areas (covered segments)
- Developing a baseline assessment plan for covered segments
- Identifying potential threats to covered segments
- Conducting pipeline integrity assessments
- Remediating conditions found during an integrity assessment
- Continually re-evaluating and re-assessing covered segments
- Performing analyses to identify preventive and mitigating measures to protect covered segments
- Identifying and tracking performance measures to assess whether the integrity management program is effective
- Maintaining required integrity program records
- Managing changes
- Implementing quality assurance processes
- Developing a communication plan
- Providing a copy of an operator’s integrity management program to a Federal or State authority as required or upon request
- Ensuring that each integrity assessment is conducted in a manner that minimizes environmental and safety risks
The following guiding principles were utilized in the development of the Williams Pipeline IMPs:
- 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.
- System integrity must be built with 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 to reduce both the number of incidents and the adverse effects of errors and incidents. The total system also includes Williams employees and third-party resources who operate the facility and use the work processes.
- 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. Williams has multiple options available to address risks:
– Components of the facility or system can be changed
– Additional training can be provided to the people who 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
- 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 can determine where the risks of an incident are the greatest, and make prudent decisions to reduce these risks.
- 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 determines the types of adverse events or conditions that 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 can make informed decisions about these issues.
- Assessing risks to pipeline integrity must be a continuous process.
Analyzing for risks in a pipeline system is an iterative process. Williams will periodically gather additional information and system operating experience and factor this information into the understanding of system risks. As the significance and relevance of this additional information to risk is understood, the integrity plan is adjusted accordingly. This change may result in adjustments to inspection methods or frequency or additional modifications to the pipeline system in response to the data. Williams will establish specific goals and measures to monitor the improvements in integrity and to assess the need for additional changes.
- New technology must be evaluated and utilized, as appropriate.
Williams 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 to apply the most appropriate technologies or techniques to a specific risk to best address potential impacts.
- Pipeline system integrity and integrity management programs must be evaluated on a regular basis.
Williams 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. Additionally, the Office of Pipeline Safety provides periodic reviews of the integrity management programs for Williams through its enforcement personnel.