In December 2016, PHMSA published an Interim Final Rule that requires operators of underground storage facilities for natural gas to comply with minimum safety standards, including compliance with API RP 1171, Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs, and API RP 1170, Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage.
In November 2017, AGA, APGA, API, and INGAA (the Associations) submitted comments on the interim final rule. The comments asked that the final rule:
- Incorporate by reference API RP 1170 and 1171 without modification of the nonmandatory provisions;
- Provide for reasonable implementation periods, consistent with PHMSA Underground Natural Gas Facility FAQs 11, 12, 15, 16, 22, and 24; 4 and,
- Incorporate underground natural gas storage facilities into a new Part of Subchapter D of PHMSA’s regulations, separate from Part 192.
In the meantime, PHMSA has issued a stay of enforcement on citations to operators for non-compliance with any provisions that are non-mandatory in the recommended practices until at least one year following publication of a final rule.
AGA anticipates the final rule to be published in 2019.