The board of directors of the Interstate Natural Gas Association of America voted February 10 to reaffirm its commitment to underground natural gas storage integrity and accelerate implementation of industry storage standards.
The board also voted to support the Pipeline and Hazardous Materials Administration advancing federal regulation of natural gas storage based on existing consensus standards.
“This vote underscores INGAA member companies’ strong commitment to pipeline and storage safety,” said INGAA President and Chief Executive Officer Don Santa. “Many INGAA members operate interstate and intrastate natural gas storage. This vote advances the underground storage safety initiative undertaken by INGAA in 2011 by building on our efforts to promote industry standards for underground gas storage integrity and by supporting accelerated adoption of recommended storage practices.”
Since its founding in 1944, INGAA and its member companies have pursued a commitment to advancing gas transmission and storage safety and integrity. In 2011, INGAA formalized this safety commitment and the goal of achieving zero incidents through the adoption of its Integrity Management Continuous Improvement initiative. IMCI is a comprehensive set of commitments and action plans intended to advance the industry’s goal of achieving zero incidents.
Building upon IMCI, in 2011, INGAA endorsed the development of industry-wide safety standards for underground natural gas storage. Since 2011, INGAA has been working with the American Gas Association, the Pipeline and Hazardous Materials Safety Administration, federal and state officials, and others to develop industry consensus safety standards to ensure the integrity of underground natural gas storage systems. As a result of this effort, the American Petroleum Institute issued two recommended practices – API RP 1170 and API RP 1170 – in September 2015. RP 1170 addresses the safe design and operation of solution-mined salt caverns used for natural gas storage, while RP 1171 addresses the integrity of natural gas storage in depleted hydrocarbon reservoirs and aquifer reservoirs.
“INGAA is strongly committed to safety – of our pipelines and of all the facilities that we operate,” Santa added. “The board strongly supports adopting these consensus standards, even in advance of any federal regulation. We also support the Pipeline and Hazardous Materials Administration promulgating federal natural gas storage rules based on the recommended practices. Because our industry is only as strong as its weakest link, federal standards for natural gas storage can help lift all boats.”
There are approximately 400 underground natural gas storage facilities in the United States. The facilities use underground geologic formations, such as depleted oil and gas wells and salt caverns, to store natural gas. There currently are no federal safety regulations for natural gas storage.
In testimony to a Senate subcommittee in September 2015, Santa said INGAA believed that PHMSA should undertake a rulemaking to adopt new regulations for underground natural gas storage and suggested that the new recommended practices would help to facilitate more rapid adoption of such rules.
INGAA also recommended that Congress, as part of the upcoming Pipeline Safety Act reauthorization, require the creation of federal regulations by a date certain. INGAA supported the appropriate delegation of oversight authority to state entities for intrastate storage facilities, similar to the existing delegation of authority for intrastate pipeline regulation.
API Recommended Practice 1170
This recommended practice (RP) applies to the safety and integrity of natural gas storage in salt caverns. It focuses on facility geomechanical assessments, cavern well design and drilling, solution mining techniques and operations, including monitoring and maintenances practices. The RP includes cavern well systems (wellhead, wellbore and cavern) from emergency shutdown valves to safety and integrity of the cavern system.
API Recommended Practice 1171
This recommended practice (RP) applies to the safety and integrity of 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. The RP includes activities in risk management, site security, safety, emergency preparedness, and procedural documentation and training.