Underground storage of natural gas is an integral component of the nation’s energy system, and our nation’s significant storage capacity enables storage operators and utilities to offer clean natural gas to consumers reliably throughout the year in a cost-efficient manner. Each Association and its member companies has a strong commitment to advancing pipeline and underground natural gas storage safety. Building upon this commitment, the Associations fully supported the development of industry-wide safety standards for underground natural gas storage, the API Recommended Practices 1170 & 1171.
Storage operators’ adoption of these Recommended Practices, as published, at all underground natural gas storage facilities will result in the most comprehensive safety enhancement to underground natural gas storage made in decades, and will apply to all aspects of the underground gas storage life cycle. That being said, PHMSA must promptly revise certain aspects of the IFR to ensure a practicable and effective final rule for underground natural gas storage facilities, including:
- Incorporate by reference API RP 1170 and 1171 without modification of non-mandatory provisions;
- Provide for reasonable implementation periods, as outlined in the attached comments and consistent with PHMSA’s published FAQs;
- Within 12 months, operators must have the foundational components of a functional integrity management system, including a written framework
- Within three years, operators must have a complete storage functional integrity management system in place, including complete written procedures and programs for training personnel
- Within 3 – 8 years, operators must complete underground gas storage facility risk assessments, including the baseline integrity assessments and preventative and mitigative measures warranted by the risk assessment.
- Incorporate underground natural gas storage facility regulations into a new Part of Subchapter D of PHMSA’s regulations, separate from Part 192.
The Associations and our members look forward to working with federal and state partners to advance our shared goal of ensuring strong and proven underground natural gas storage integrity. We appreciate PHMSA’s consideration of these comments.