Underground Natural Gas Storage: FAQs

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These Frequently Asked Questions (FAQs) are intended to clarify, explain, and promote better understanding of issues concerning integrity assessment of Underground Natural Gas Storage Facilities. These FAQs are not substantive rules and do not create rights, assign duties, or impose new obligations not outlined in the existing regulations and standards. Requests for informal interpretations regarding specific situations may be submitted to PHMSA in accordance with 49 C.F.R. §190.11.

The Underground Natural Gas Storage (UGS) regulations in §192.12 (a) through (d) state that each underground natural gas storage facility that uses a solution-mined salt cavern reservoir, depleted hydrocarbon reservoir, or an aquifer reservoir for gas storage must meet the design, construction, operations, maintenance, integrity demonstration and verification, monitoring, threat and hazard identification, assessment, remediation, site security, emergency response and preparedness, and recordkeeping provisions of the American Petroleum Institute (API) Recommended Practices (RP) 1170 or 1171. These frequently asked questions (FAQs) are designed to assist operators and the public in understanding the application of the regulations to UGS facilities. Note that PHMSA has not yet issued the final UGS rule. These FAQs are subject to change.

To download a copy of the FAQs, click here.

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Superseded: 04/03/2017

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8. When does the notification requirement for existing and new UGS facilities under §§ 191.15, 191.17, 191.22, and 191.23 take effect?

The notification requirements for incident, national registry, and safety-related condition reporting became effective on January 18, 2017 (the effective date of the rule).

Under §191.17, the first annual report (for calendar year 2016) is due by July 18, 2017. Subsequent annual reports will be due by March 15, for the previous calendar year.

Original: 04/03/2017

9. What notifications are required for underground storage facilities? §191.22(c), requires underground storage facility operators to submit notifications to PHMSA electronically through the “National Registry of Pipeline, Underground Natural Gas Storage Facility, and LNG operators” at http://opsweb.phmsa.dot.gov. After initially obtaining an Operator Identification Number for an existing or new facility, further notifications are required to report changes to a UGS facility, or abandonment, drilling, or well workover (including replacement of wellhead, tubing, or casing) of an injection, withdrawal, monitoring, or observations well. Replacement means the complete removal of the existing component and replacement with a new component (including replacement of wellhead, tubing, or casing). Operators are not required to notify PHMSA of routine maintenance or repairs to existing components. In addition, operators must report a change in the entity (including company, municipality, etc.) that is responsible for an existing UGS facility and the acquisition or divestiture of an existing UGS facility.

Original: 04/03/2017

10. Are individual notifications specified in §191.22(c) required for every activity that meets the notification requirement?

Multiple activities within the same storage field may be reported within a single notification. Separate notifications are required for each storage field.

Original: 04/03/2017

11. What procedures must operators of UGS depleted hydrocarbon reservoirs or aquifer reservoirs constructed on or before July 18, 2017 have in place by January 18, 2018?

Procedures for each storage facility, in accordance with §192.605, must be completed that address operating, maintenance, emergency preparedness, and any physical site work activities that are being conducted as of January 18, 2018. For activities that are not being conducted as of January 18, 2018, completed procedures must be in place before conducting those future activities. For such future activities, appropriate initial procedures should be in place by January 18, 2018 and should include, but not be limited to:

  • Foundational components of an operator’s UGS functional integrity management program
  • Guidance for the development of procedures for activities required in the future
  • A specific breakout of how the applicable Recommended Practice requirements would be addressed in the management system framework and procedures
  • The roles and responsibilities of staff committed to the development and implementation
  • How staff will be trained in awareness and application of the procedures
  • An implementation schedule, that is based on risk analysis and could change with new information and advances in technology for well assessments including any planned preventative and mitigative measures, and any planned remediation

The procedures, implementation plans, and schedules must be sufficient for long-term implementation of the requirements and recommendations in API RP 1171, sections 8, 9, 10, and 11, as specified in §192.12(d). PHMSA expects each operator’s procedures, implementation plans, and schedules will evolve into a more detailed, comprehensive and robust program as the operator’s program matures.

Original: 04/03/2017

12. What procedures must operators of UGS solution-mined salt caverns constructed on or before July 18, 2017 have in place by January 18, 2018?

Procedures for each storage facility, in accordance with §192.605, must be completed that address operating, maintenance, emergency preparedness, and any physical site work activities that are being conducted as of January 18, 2018. For activities that are not being conducted as of January 18, 2018, completed procedures must be in place before conducting those future activities. For such future activities, appropriate initial procedures should be in place by January 18, 2018 and should include, but not be limited to:

  • Foundational components of an operator’s UGS functional integrity management program
  • Guidance for the development of procedures for activities required in the future
  • A specific breakout of how the applicable Recommended Practice requirements would be addressed in the management system framework and procedures
  • The roles and responsibilities of staff committed to the development and implementationn
  • How staff will be trained in awareness and application of the procedures
  • An implementation schedule, that is based on risk analysis and could change with new information and advances in technology for well assessments including any planned preventative and mitigation measures, and any planned remediation

The procedures, implementation plans, and schedules must be sufficient for long-term implementation of the requirements and recommendations in API RP 1170, sections 9, 10, and 11, as specified in §192.12(b). PHMSA expects each operator’s procedures, implementation plans, and schedules will evolve into a more detailed, comprehensive and documented robust program as the operator’s program matures.

Original: 04/03/2017

13. How will PHMSA determine the date of construction?

§192.12 states that UGS facilities “constructed after July 18, 2017” must meet all requirements and recommendations of API RP 1170 or API RP 1171, as applicable, including design, construction, testing, and commissioning requirements. Thus, §192.12(a) or (c), as applicable, applies to UGS facilities that commence physical onsite construction activities after July 18, 2017.

Realizing projects can take many months to plan and implement, the extended construction requirement date of July 18, 2017 allows the completion of construction work (including design, drilling, material, construction, and completions) with the design and materials that have been purchased prior to IFR publication.

Original: 04/03/2017

14. How are local or state licenses and permits for UGS impacted by the new IFR regulations??

PHMSA is not responsible for siting determinations and does not prescribe the location of any facilities. Operators remain responsible for obtaining and renewing any federal, state, or local licenses, permits, or certificates.

Original: 04/03/2017

15. What procedures must operators of UGS depleted hydrocarbon reservoirs or aquifer reservoirs constructed after July 18, 2017 have in place as the July 18, 2017 date approaches?

As required in §192.12(c), operators of UGS depleted hydrocarbon reservoir or aquifer reservoir facilities constructed after July 18, 2017 must have design and construction procedures in place that meet API RP 1171 prior to the start of physical construction. As required in §192.12(d) and API RP 1171, Sections 8, 9, 10, and 11, operators must have procedures for operations, maintenance, and emergencies for the newly constructed facilities incorporated into their written procedures for operations, maintenance, and emergencies established pursuant to § 192.605 prior to initial operations.

Original: 04/03/2017

16. What procedures must operators of UGS solution-mined salt caverns constructed after July 18, 2017 have in place as the July 18, 2017 date approaches?

As required in §192.12(a), operators of UGS solution mined salt cavern facilities constructed after July 18, 2017 must have design and construction procedures in place that meet API RP 1170 prior to the start of physical construction. As required in §192.12(b) and API 1170, Sections 9, 10, and 11, operators must have procedures for operations, maintenance, and emergencies for the newly constructed facilities incorporated into their written procedures for operations, maintenance, and emergencies established pursuant to § 192.605 prior to initial operation.

Original: 04/03/2017

17. Does the IFR allow operators of UGS facilities to deviate from the non-mandatory recommendations in the recommended practices?

Applicable non-mandatory recommendations in the RPs are mandatory unless a deviation is technically justified and documented by the operator. Section 192.12(f) specifies two criteria (impractical or not necessary for safety, only one of which must be met) operators may use to justify the deviation. The justification for the deviation must be technically reviewed and approved in accordance with §192.12(f). Deviations that have been technically reviewed and approved do not require future reviews and approval unless operating conditions change. Documentation for all deviations must be available for inspection by regulatory authorities. Documentation must be established and maintained in accordance with 49 U.S.C 60117 for as long as the operator deviates from the recommended practice.

Original: 04/03/2017

18. When must operators document deviations from the non-mandatory recommendations in the recommended practices?

Deviations for activities that are currently being implemented for facilities constructed not later than July 18, 2017 must be documented by January 18, 2018.

Deviations from design and construction requirements for facilities constructed after July 18, 2017 must be documented prior to the start of physical construction.

Deviations from operations and maintenance (O&M) requirements for facilities constructed after July 18, 2017 must be documented prior to initial operations.

For all facilities, the operator would be expected to develop and document future or newly identified deviations as future operations or activities evolve and document those deviations before the activities addressed by the future deviation are performed.

Original: 04/03/2017

19. Does replacement, expansion, or addition of components or appurtenances on existing storage wells require compliance with all provisions of API RPs 1170 or 1171, as applicable?

Such activities are considered maintenance activities for purposes of compliance with §192.12. Maintenance activities must comply with API RP 1170 or 1171, as applicable.

Original: 04/03/2017

20. What requirements apply for a well that is repurposed or a new well that is constructed at an existing UGS facility?

New storage wells or repurposed non-storage wells (e.g., production or abandoned wells), for which physical onsite construction begins after July 18, 2017 at an existing UGS field, must comply with all requirements of the applicable API RP in accordance with §192.12(a) or (c). For any existing, in-service storage well that is repurposed as a different type of storage well, any casing, tubing, packers, or wellhead that is replaced must meet the requirements in §192.12(a) or (c).

Original: 04/03/2017

21. May operators revise their implementation plan and general timeline?

The operator’s initial implementation plan and general timeline must be established based upon site-specific information known by the operator by January 18, 2018. The plan and timeline will likely change over time as new data is collected and evaluated during the on-going risk analysis process. Operators are expected to revise the plan and timeline as new integrity information is acquired from assessments outlined in API RP 1170 and 1171.

Original: 04/03/2017

22. What are PHMSA’s expectations for UGS safety risk analyses and assessment work, given that some of the provisions in the recommended practices may take several years to fully complete or implement?

The implementation plan and general timeline should address the risk analysis and threats including the timing of assessment work as described in API 1170, Section 10, and API 1171, Section 8, as applicable. Preventive and mitigative measures must be scheduled commensurate with the specific risks identified for each well and the overall risks identified for the storage field.

In most cases, PHMSA expects UGS operators to complete a risk assessment including preventive and mitigative measures for all wells, within 3 to 8 years from the effective date of the rule, depending on the size and complexity of the facility and as warranted by the risk assessment. PHMSA also expects that operators will prioritize implementation of preventive and mitigative measures for wells with higher risk.

Original: 04/03/2017

23. What will initial regulatory inspections entail?

Initial inspections by PHMSA or States will likely focus on reviewing written procedures and implementation plans to assure technical adequacy and specificity for compliance with API’s RPs and §192.12. These initial inspections will also review technical justifications for deviations that have been employed per §192.12(f) as of the date of the inspection. PHMSA anticipates that initial inspections would commence approximately one year after the effective date of the rule.

Original: 04/03/2017

24. What is the expected overall timeline for baseline assessments?

PHMSA expects that each operator will start baseline assessments within two years of the effective date of the rule, with priority on higher risk wells identified in the risk analysis process. In most cases, PHMSA expects that each operator’s baseline assessments and initial preventive and mitigative measures in all storage fields will be completed within 3 to 8 years from the effective date of the rule, depending on the size and complexity of each storage field and as warranted by the risk assessment.

Original: 04/03/2017

25. Can an operator take credit for a prior integrity assessment to avoid duplicating work previously performed?

An operator may use a prior integrity assessment that was completed prior to the effective date of the rule, if a technically acceptable justification is documented and maintained in facility records. Prior integrity assessments must meet the requirements of API RPs 1170 or 1171, as applicable, and must be valid for the current operating conditions and operating environment. When evaluating prior integrity assessment results, operators must account for the growth and effects of indicated defects over time since the integrity assessment was performed. If the operator uses a prior integrity assessment that does not meet all applicable requirements of API RPs 1170 or 1171, a deviation must be documented as required by §192.12(f).

Original: 04/03/2017

26. Has a timeframe for second round assessment been established?

Criteria and timing for re-assessments should be determined using results from baseline assessments and updated risk analyses, as required in API RP 1170, Section 10 and API RP 1171, Section 8.

Original: 04/03/2017

27. Must UGS facilities have a Drug and Alcohol Testing Program?

Yes. Because the API RPs do not address drug and alcohol testing, operators of underground gas storage facilities must comply with 49 CFR Part 199. Any operator of a pipeline facility that is subject to even a subset of the Part 192 regulations is required to test covered employees for the presence of prohibited drugs and alcohol. A covered employee is a person who performs a covered function, including persons employed by operators, contractors engaged by operators, and persons employed by such contractors. Covered functions include operations, maintenance, or emergency-response functions that are performed on the pipeline facility.

Original: 04/03/2017

28.Must operators of UGS facilities comply with Part 192, Subpart N, Qualification of Pipeline Personnel?

No. Operators must comply with the training requirements in API RP 1170 (Section 9.7.5) or API RP 1171 (Section 11.12), dependent on the type of storage field. Both describe general training parameters and specifically identify the need to train personnel for normal, abnormal, and emergency conditions.

Original: 04/03/2017