Spill Prevention Control

As a midstream oil and gas company, spill (also known as release) prevention and control is fundamental to the preservation of the environment surrounding our operations. We customize emergency response plans for each of our assets to prevent incidents and respond safely and quickly in an emergency. We also work closely with our local communities, contractors and employees to ensure all parties know their roles and responsibilities in the event of a spill or emergency situation.

Approach

Our senior vice presidents of operations are responsible for spill prevention control. The monitoring and implementation of emergency response processes are managed by our operational, pipeline compliance and transportation safety personnel. By applying key asset integrity processes throughout design, construction and prior to in-service of facilities, we identify potential hazards and install mitigation controls to prevent spills and emergency events whenever possible.

Asset Integrity

The Asset Integrity team is responsible for assisting operations in safeguarding the health and safety of Crestwood employees and the public while ensuring the integrity, reliability and efficiency of our assets. Comprised of engineers, corrosion specialists, GIS professionals and field technicians, our team develops and implements Crestwood’s comprehensive Asset Integrity Management Program. The goal of this program is to minimize operational risk, maintain asset value, meet regulatory responsibilities and improve the efficiency of Crestwood assets. Our Asset Integrity Management Process is rooted in sustainability, with a full-cycle design to promote operational accountability and stability. Executing this strategy requires application across the entire lifecycle of our assets: development, design, construction, testing, operation and decommissioning.

Our strategic program is essential to building or modifying a new or existing asset, in addition to integrating legacy assets from acquisitions. The program is designed around the Plan-Do-Check-Act continual improvement cycle, a management method that includes the following aspects:

  • Risk Assessment - Identify and assess potential risks to assets from multiple sources. Prioritize risks based on their likelihood and consequences and define the controls and barriers necessary to eliminate or reduce the risks.
  • Measurement, Evaluation & Corrective Action - Evaluate inspection results, take additional measurements and implement corrective action as necessary.
  • Management Review & Improvement - Complete a formal asset integrity review to determine that assets are fit for continued service. Establish the appropriate reassessment interval and identify modifications to the plan for the next cycle.

The use of geographic information system (GIS) and geospatial technology enables us to conduct a variety of inspections, track assessments and review corrective actions. Our team communicates with internal stakeholders so all parties have the necessary information to make informed decisions regarding business processes and performance. In 2020, we also initiated a full records audit of our pipelines and began a gap analysis to develop plans to comply with the new Mega Rule established by the Department of Transportation (DOT).

Operational Safety
Pipeline Inspections1

2020
2019
2018
Percentage of natural gas pipelines inspected
0.0%
0.0%
0.0%
Percentage of hazardous liquid pipelines inspected
31.3%
8.9%2
4.3%2
  1. Inspections are on regulated lines only. Inspection activities include those listed under U.S. 49 CFR 192 for gas pipelines and U.S. 49 CFR 195 for liquid pipelines.
  2. Data from 2018 and 2019 has been restated based on recent updates to our database capturing a holistic data set.

Our percentage of natural gas lines inspected is zero because DOT-regulated gas pipelines are required to be inspected every seven years. Gas pipelines due for inspection during the reporting periods reflected in data are Joint Venture-owned, which are excluded from this report to align with our financial reporting. The percentage of hazardous liquid pipelines inspected increased compared to 2019 due to our acquisition of assets from Plains All American Pipeline in April 2020.

Spill Prevention and Control Measures

We follow pertinent State and Federal Environmental Protection Agency regulations for the prevention of, preparedness for and response to spills. Our response plans include:

  • Facility Spill Prevention, Control and Countermeasure (SPCC) Plans
  • Risk Management Plans (RMPs)
  • Emergency Response Plans (ERPs)

These three plans contain clear monitoring and prevention responsibilities and instructions outlining how to safely and quickly reduce the impact of a potential spill on the surrounding environment, while ensuring the safety of our people and contractors. We also provide response training for our operations personnel.

Our Operations team monitors and conducts inspections of our natural gas liquid (NGL), crude oil and produced water pipelines every hour from our control centers, as outlined in our Operations and Maintenance Manual. We also periodically conduct inspections of our NGL, water and oil pipelines that are monitored by fail-safe pressure controls and alarms. When a fail-safe alarm is triggered, our control center employees work through a checklist to understand why it was triggered. If a problem is identified, the control center notifies our field operators who then physically inspect the pipeline section to address the problem. In addition to physical inspections, we periodically send smart pipeline inspection gauges (PIGs) through our pipelines to inspect the condition of the pipe and proactively identify any potential issues. Any issues identified by physical inspection or smart PIGs are quickly corrected to prevent a spill or other emergency. 

If a spill or emergency incident does occur, we take immediate action to remediate any impacts. After all incidents, we conduct a root-cause analysis to understand why the incident occurred and implement measures to prevent the incident from reoccurring. Similar to our crude oil pipelines, we also monitor our produced water lines to ensure they are operating within their designed pressures. In the event of an emergency, we are able to immediately shut down or block off a pipeline, quickly and efficiently limiting the potential impact. As part of our annual Emergency Response Plan reviews, we ensure that our response equipment is properly maintained and appropriate for the area and hazards. Crestwood operates a 24/7 emergency hotline for our workers and the general public to report any emergencies, suspicious activities, environmental or safety issues, spills, pipeline bursts or other events. These reports are then escalated to operations for response and action.

Geohazard risks, including land slips, frost heave, flooding or erosion, exist in certain areas where we operate. In these locations, we conduct geohazard assessments to evaluate potential risks. We first identify the types of hazards in the area and determine where exposure to these hazards is the highest. Where possible, we avoid routing a pipeline through a hazardous area, and in some cases, we may adjust our construction plans entirely.

Transportation

Ensuring we maintain the safest processes for handling and transporting crude oil and NGL by using heavy-fleet and rail is of the utmost importance to Crestwood. We have developed comprehensive, location-specific Hazardous Materials Transportation Security Plans which outline possible security risks and the appropriate mitigation measures for transportation, storage and unloading of hazardous materials. To ensure plan effectiveness in an emergency and compliance with all federal requirements, we frequently review and test our Transportation Emergency Response Plan.

Crestwood is also actively engaged with TRANSCAER®, a national organization focused on assisting communities to prepare for and respond to possible hazardous materials transportation incidents. Through this partnership, our training trailer is used for events that enable community discussion and increase public awareness of the safety systems we use to reduce risk of transportation incidents. Through TRANSCAER®, we also train first responders in the communities in which we operate to ensure they are prepared for any emergency that may arise.

Spill Prevention Control

2020
2019
2018
Total reportable releases
3
20
6
Number of hydrocarbon liquid releases beyond secondary containment (>5 bbl)1
1
10
4
Volume of hydrocarbon liquid releases beyond secondary containment (>5 bbl)1
30
6,260
151
Hydrocarbon Liquid Releases intensity per Mile of Pipeline
0.02
3.66
0.10
Volume in Arctic (bbl)
0
0
0
Volume in unusually sensitive areas (bbl)
0
4
0
Volume recovered (bbl)
0
68
0
Reportable pipeline incidents
-Number
0
0
0
-Significant pipeline incidents (%)
0%
0%
0%
Rail transportation releases
-Number of accident releases
0
0
0
-Number of non-accident releases
0
0
0
  1. We have updated our spill reporting methodology to align with the EIC/GPA ESG reporting template.

Preventing Spills in North Dakota

In late 2019, we conducted an analysis of our Arrow produced water gathering system and proactively decided to idle and/or replace the remaining Fiberspar portions of the system with Flexsteel. This decision was driven by Crestwood’s ongoing sustainability initiatives and a series of produced water releases that occurred after Crestwood acquired the system in 2013 from a private midstream operator. We completed the project in 2020.

Crestwood’s proactive decision to idle and/or replace portions of the Arrow produced water gathering system is consistent with our commitment to safety and sustainability. It also showcases our commitment to the MHA Nation and the state of North Dakota to exceed regulatory requirements to ensure the produced water gathering system functions safely and effectively going forward.

Looking Ahead

Our Asset Integrity Management Program is ever evolving, and we will continue to evaluate and strategically employ new technologies. We will also continue to diligently monitor emerging regulatory impacts and any population and physical changes along our pipeline rights-of-way.

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