If you are a natural gas operator, it is likely your regulatory focus is currently on development and implementation of Part 1 of the Gas Transmission Rule, A.K.A the “Mega Rule”. Though this rulemaking was significant the Pipeline and Hazardous Materials Safety Administration (PHMSA) has continued to issue new rules regarding underground natural gas storage facilities. Elemental experts are available to assist operators with meeting regulatory deadlines associated with the recent rulemaking, allowing operators to continue to focus on Mega Rule requirements.
On February 12, 2020 PHMSA published the Safety of Underground Natural Gas Storage Facilities (UNGSF) Final Rule. The UNGSF Final Rule integrates comments received on the Interim Final Rule (IFR) published December 19, 2016
For UNGSFs constructed prior to July 18, 2017, regulatory deadlines for the implementation of specified portionsof API RPs 1170 and 1171 went into effect January 18, 2018 under the IFR. With the publication of the UNGSF Final Rule, there are additional critical deadlines to be aware of including:
Additionally, salt caverns constructed after March 13, 2020 must meet all requirements of API RP 1170 and Section 8, Risk Management for Gas Storage Operations, of API RP 1171. Salt caverns constructed prior to this date are required to meet Sections 9, Gas Storage Operations; 10, Cavern Integrity Monitoring; and 11, Cavern Abandonment, of API RP 1170 and Section 8, Risk Management for Gas Storage Operations of API RP 1171.
Whether you are looking for assistance with process development, risk assessment development, or simply a gap analysis of existing processes and assessments, contact us at Nicole.Tebow@ElementalCompliance.com or Lauren.Tipton@ElementalCompliance.com to discuss how we can help you reach your UNGSF compliance goals.
Stay tuned to Elemental Compliance’s LinkedIn page and Blog for further regulatory updates.
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