In January 2020, PHMSA will publish a new final rule to the federal registry recommending new safety standards for Underground Natural Gas Storage Facilities (UNGSF).
The final rule addresses critical safety issues related to downhole facilities, including well integrity, wellbore tubing, and casing.
According to a PHMSA news release, these standards will directly apply to approximately 400 facilities (200 interstate facilities and serve as the minimum federal standard for approximately 200 intrastate facilities).
The main point of emphasis for operators of UNGSFs across the U.S. is that the Control Room Management Rule (CRM Rule) will apply more broadly to gas storage.
What Prompted the New Final Rule for UNGSFs?
From the period of October 2015 to February 2016, a natural gas leak near Aliso Canyon, California released approximately 4.62 billion cubic feet of natural gas into the atmosphere.
Following the discovery of this release from an underground storage facility, the PIPES Act of 2016 required PHMSA to enact minimum federal safety standards for UNGSF and address safety concerns.
“The Aliso Canyon incident was one of the largest natural gas releases in U.S. history and affected the lives of thousands of Americans living and working nearby,” said PHMSA Administrator Skip Elliott in the news release. “Compliance with this rule will go a long way toward preventing an incident of that magnitude from happening again.”
The final rule incorporates by reference API RP 1170 and 1171 to establish the pipeline safety standards for several types of underground facilities and provides a minimum federal standard for inspection, enforcement, and training.
– API RP 1170 (Design and Operation of Solution-Mined Salt Caverns Use for Natural Gas Storage). This recommended practice was published in July 2015 to provide the functional recommendations for salt cavern facilities used for natural gas storage service. The RP covers facility geomechanical assessments, cavern well design & drilling, solution mining techniques & operations, including monitoring, and maintenance practices.
– API RP 1171 (Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs). This recommended practice, which was published in September 2015, applies to natural gas storage in depleted oil and gas reservoirs and aquifer reservoirs. The RP focuses on storage well, reservoir, and fluid management for functional integrity in design, construction, operation, monitoring, maintenance, and documentation practices. API 1171 also recommends that operators manage integrity through monitoring, maintenance, and remediation practices and apply specific integrity assessments on a case-by-case basis.
How Are Operators Affected by the New Final Rule?
The approximately 400 facilities brought under the CRM Rule will be subject to inspection. Some facilities will be inspected by PHMSA, while other facilities will be inspected by the state agency responsible for maintaining the integrity of intrastate pipelines.
Then, there are the wells that will be brought under federal jurisdiction for inspection. PHMSA estimates there are 17,542 wells to be inspected.
Overall, PHMSA has a five-year plan to inspect all facilities and wells that are subject to inspection.
During the transition period for operators, PHMSA will be providing ample resources to help operators satisfy inspections of facilities and wells.
What’s Next After the Final Rule is Published?
Now that the final rule for Underground Natural Gas Storage Facilities has been published, PHMSA will be taking these follow-up steps:
- Revised Inspection Question Set
- Revised FAQs on the final rule
- Sustained TQ classes (Inspector Training and Qualifications)
- Public Workshop to discuss the rule
- Initiation of Annual UNGS Conference
The goal is two-fold:
– Provide operators with information and a forum to better understand what is required of them to satisfy the CRM Rule as it pertains to UNGSFs.
– Beef up inspection efforts by providing inspectors with specialized training for understanding and applying federal pipeline safety regulations and standards incorporated by reference.
How is CRM Coverage Determined Under the New Gas Storage Rule?
Here is a quick analysis of the new rule, and it’s applicability. Our analysis starts with the scope.
§192.1 — What is the scope of this part?
(a) This part prescribes requirements for the reporting of incidents, safety-related conditions, annual pipeline summary data, National Operator Registry information, and other miscellaneous conditions by operators of underground natural gas storage facilities and natural gas pipeline facilities located in the United States or Puerto Rico, including underground natural gas storage facilities and pipelines within the limits of the Outer Continental Shelf as that term is defined in the Outer Continental Shelf Lands Act (43 U.S.C. 1331).
This new wording clearly includes underground natural gas storage facilities into the scope of Part 192. Additional analysis of definitions finds the following:
Pipeline means all parts of those physical facilities through which gas moves in transportation, including pipe, valves, and other appurtenance attached to pipe, compressor units, metering stations, regulator stations, delivery stations, holders, and fabricated assemblies.
Pipeline facility means new and existing pipelines, rights-of-way, and any equipment, facility, or building used in the transportation of gas or in the treatment of gas during the course of transportation.
Transportation of gas means the gathering, transmission, or distribution of gas by pipeline or the storage of gas, in or affecting interstate or foreign commerce.
Underground natural gas storage facility means a gas pipeline facility that stores natural gas in an underground facility, including a depleted hydrocarbon reservoir, an aquifer reservoir, or a solution-mined salt cavern reservoir.
How Can EnerSys Help Operators?
The new PHMSA gas storage rule has been in the works for some time. Now that the final rule has been published, it’s time to start thinking about your assets that will be brought into compliance with the CRM Rule.
Our company specializes in control room management software and consultation.
We will work with your team to outline a plan to update policies and procedures, create understanding of how to achieve compliance naturally in the control room, and utilize our Control Room Management Suite (CRM Suite) software for recordkeeping, document management, electronic logging, alarm rationalization, and audit support.
We would appreciate the opportunity to discuss how we can support your operation achieve compliance with the new PHMSA gas storage rule.