On October 20, 2017, PHMSA issued the “Underground Gas Storage Facility Safety Site Assessment Report.” The document reviews PHMSA’s assessment of eight underground storage sites throughout the continental US. A team of PHMSA inspectors and underground natural gas storage (UGS) subject matter experts visited these facilities from May to July 2017. These site assessments were conducted in preparation for a January 18, 2018 deadline, when the UGS Interim Final Rule goes into effect and where mandatory and non-mandatory provisions set forth in API Recommended Practices 1170 and 1171 are to be made mandatory for UGS operators nationwide. In June 2017 after some site assessments had already been completed, PHMSA softened their stance and issued a statement that no non-mandatory provisions in API 1170 and 1170 will be enforced until January 18, 2018 at the earliest (see related articles in the July edition of the DOT Pipeline Compliance News).
The site assessments were voluntary and not classified as inspections – thereby no deficiencies, notices, reports, or enforcement actions were made by PHMSA. The assessments took place in California, Colorado, Illinois, Louisiana, Mississippi, Michigan and Texas and encompassed five depleted fields, three salt cavern fields, and one aquifer field. These site assessments were conducted at operating fields so PHMSA’s main focus was on operating and maintenance factors aspects of the API RPs. Each assessment visit consisted of high-level discussions with respective UGS personnel, a half-day site tour, and a detailed questionnaire filled out by the personnel. These questions focused mainly on Procedures & Training; Site Security & Safety, Site Inspections, and Emergency Response; Integrity Demonstration, Verification & Monitoring; and Risk Management. PHMSA summarized observations from these four categories within the document. Each assessment took an average of 2-1/2 days to conduct.
PHMSA expects to issue the Final Rule for UGS in early 2018. For a copy of this report, contact Jessica Foley.