Corporate Social Responsibility

Regulatory Compliance

Commitment to Compliance

Williams’ management system, Williams Integrated Management System (WIMS), contains procedures outlining how all permits and applicable regulations will be analyzed to determine what actions are required to ensure ongoing compliance. All regulatory and other internal company environmental requirements are entered as tasks in Gensuite Compliance Calendar and tracked to completion.

Procedures and standards included in WIMS:

Air Quality Management: Establishes the standard air quality management process for the construction, operation and maintenance of assets within the United States that have the potential for emitting regulated pollutants.

Waste Management: Establishes the standard method for managing hazardous and nonhazardous waste (gaseous, liquid, or solid) at company sites, including waste characterization, storage, handling, packaging, transporting, disposal and reporting.

Remediation Management: Establishes a standard method for managing environmental remediation that is required as a result of historical releases or post-emergency response cleanup operations at company sites.

Spill Prevention and Response Plans: Identifies actions required to comply with oil pollution prevention regulatory requirements at company-owned/operated assets.

Unanticipated Discovery of Environmental Contamination: Establishes the practices to employ in the event of an unanticipated discovery of contaminated soil, groundwater, waste or other potential environmental contamination conditions during construction or maintenance activities at company facilities or right of ways.

Environmental Notice of Violation Process: Establishes the process to document and resolve Environmental Notices of Violation (NOVs). Resolution is tracked through closure and relevant metrics are reported.

Greenhouse Gas Reporting: Establishes a standard method for reporting greenhouse gas (GHG) emissions for onshore and offshore company-owned assets located in the United States.

Environmental Compliance Assurance: Establishes the process for the use of the Gensuite Compliance Calendar as the official system of record for environmental compliance assurance.

In addition to the programs listed above, we have implemented the following processes and procedures on a regional basis:
  • Water Quality Compliance and Wastewater Management
  • Spill Plan for Oil and Hazardous Materials (Construction Spill Plan)
  • SARA Title III Inventory Reporting
  • Inspection of Tanks and Drums Containing Oil
  • Management of Pipeline Coatings Containing PCBs
  • Sampling Pipeline Coatings for PCBs

Monitoring & Measurement

Environmental metrics are tracked in Gensuite and reported to all employees each week. Measurement against company goals is also monitored and reported to management monthly. Additionally, environmental compliance task due dates are monitored in the Gensuite Compliance Calendar, with weekly reports generated and sent to area leadership teams.

Stimulating Continual Improvement

Action Item Management establishes the requirements for entering, tracking, resolving and closing critical action items. Action Items from many sources are added to the Action Item Tracking System, including Audits/Assessments, Incident Investigations,  Concern Reports and Regulatory Agency Inspections.

 

Continuous Improvement is an ongoing effort to improve safety, reliability, compliance and performance by incorporating lessons learned, best practices and new ideas for working more efficiently and effectively into the way we work. The best ideas for improving the way we work come from the everyday experiences and observations of those actually doing the work.

External Environmental Audits

External environmental audits have been conducted through 2018. In 2018, as part of our internal Environmental Assessment Program, a third party will conduct two of the six scheduled audits. Additionally, we contracted an external design assessment of the EHS Management System Framework (now WIMS Fundamentals and Framework) in 2013.

 

Internal Environmental Audits

WIMS Element 12 on Assurance & Continuous Improvement focuses on the various audits, assessments and inspections that are conducted to evaluate compliance with WIMS and on activities to continually improve safety, efficiency and reliability. Our ongoing management and success requires timely and objective information on successes and opportunities. We periodically conduct internal compliance self-assessments and appropriate external compliance assessments. Results of assessments are used to improve company performance and processes through documenting and tracking action items to completion.

 

The WIMS/EHS Assurance Team conducts EHS audits periodically at all of our facilities per WIMS 12.01.00.01 – WIMS Assessments. Additionally, in 2017 the Environmental Services group reinstated an internal Environmental Assessment Program and began detailed field compliance assessments in 2018. Program documentation will be integrated into WIMS in 2018.

Reporting

The leadership of each of our operating areas is responsible for implementing management systems with appropriate Operating Requirements, Operating Guidelines, Site-Specific Procedures and other standards to comply with company expectations and compliance.

 

Our executive officer team established a WIMS Steering Committee, comprised of senior level leaders from the operating areas, Engineering Services and the Safety & Operational Discipline groups. The WIMS Steering Committee meets monthly and approves WIMS documents and provides vision, direction and accountability for WIMS.

 

The EHS Committee of the Williams Board of Directors receives reports from senior level EHS leaders at least quarterly on environmental and safety metrics, including spills, accidents and safety or environmental violations. Additionally, topics such as internal audit results and incident investigations are included on the agenda.

 

In addition to reporting to the Williams Board of Directors, our leadership team and all employees receive weekly metrics reports and Continuous Improvement advisories. As a company, we meet our external requirements on greenhouse gas and emissions reporting, SARA, CERCLA, EPCRA, RCRA and other regulatory-driven reports, and include environmental liability information to our shareholders in our 10-K report.

Policies & Standards

For a full list, please visit our Policies & Standards page.