Underground Natural Gas Storage Facility Final Rule
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. These include:
o Changed the incorporation of American Petroleum Institute (API) Recommended Practices (RPs) 1170, Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage, and 1171, Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs, so that “should” and “may” statements are no longer mandatory provisions, requiring written justifications for deviations
o Added paragraph 192.12(c) to specify the requirement for operations, maintenance, and emergency preparedness and response activity manuals and annual updates
o Added paragraph 192.12(d) to formalize integrity management requirements, including a plan for developing and implementing each element, a procedure outline, roles and responsibilities, a staff training plan, implementation timeframes for each element, and a continuous improvement plan for incorporating experience
o Added a requirement that salt caverns must meet the requirements of API RP 1171 Section 8, Risk Management for Gas Storage Operations
o Reduced the scope of reportable events
o Revised the definition of an underground natural gas storage facility to clarify delineation between above ground pipeline facilities, production gas storage, and UNGSFs and clarifies that only paragraph 192.12 applies to UNGSFs
o Changed the name of the reporting portal to ‘‘National Registry of Operators’’, formerly the ‘‘National Registry of Pipeline and LNG Operators’’
For UNGSFs constructed prior to July 18, 2017, regulatory deadlines for the implementation of specified portions of 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:
o Meet provisions of paragraph 192.12(d) by March 13, 2021
o Complete 40% of risk assessments for wellbore, wellhead, and associated components by February 12, 2024 (prioritizing higher-risk wells first)
o Complete 100% of risk assessments for wellbore, wellhead, and associated components by February 12, 2027
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.