December 14, 2016
Don Santa, president and CEO of the Interstate Natural Gas Association of America, today commented on a new Pipeline and Hazardous Materials Administration interim final rule to regulate natural gas storage:
“INGAA strongly supports PHMSA regulation of natural gas storage based on consensus standards. We are quite concerned, however, that the 12-month implementation period outlined in the interim final rule is unrealistic. Extensive effort will be required to implement a structured and documented integrity management program across the roughly 400 underground gas storage facilities in the United States.
“INGAA’s members are strongly committed to safety – of the pipelines and all of the facilities that they operate. For that reason, INGAA’s board in February supported voluntary adoption of these consensus standards in advance of any federal regulation. And we supported PHMSA promulgating federal natural gas storage rules based on those recommended practices to ensure consistency in implementing those practices across all underground storage operators. We are concerned that a rushed 12-month implementation of the entirety of the recommended practices would impose a substantial burden on operators and could undermine the effectiveness of these risk-based integrity management programs. In contrast, the implementation period for the gas transmission pipeline integrity management program requirements was ten years.
“We are reviewing this interim final rule, and hope PHMSA will take our concerns into consideration.”
INGAA is the North American trade association representing the interstate and interprovincial natural gas pipeline industry. INGAA’s members operate approximately 200,000 miles of pipelines, and serve as an indispensable link between natural gas producers and consumers.
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.
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.
Download the full press release here.