December 2016 Vol. 71 No. 12
Washington Watch
Interim Gas Storage Regulations Upcoming from PHMSA
Interim regulations from the Pipeline and Hazardous Materials Safety Administration (PHMSA) on natural gas storage facilities are imminent. They are not likely to be terribly controversial since PHMSA says they will be based on two industry voluntary standards: API Recommended Practices 1170 and 1171. Both of those are fully supported by pipeline groups. Both were adopted in 2015 in the wake of the leak at SoCalGas’s Aliso Canyon facility, the largest ever in the U.S.
There are 415 underground gas storage facilities in the U.S. and split almost evenly between interstate and intrastate. However, permanent regulations scheduled to be finalized within the next two years may be more onerous.
The near-term adoption of the RP1170 and 1171 as federal law was recommended in mid-October by a federal task force under the Department of Energy which was created by the terms of the Protecting our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2016. That law gave PHMSA two years to establish a new standard which would jump off from the task force’s 44 recommendations but may well exceed the requirements of RP 1170 and 1171. There will be an interim rule before the final rule is issued.
API RP 1171 addresses storage in depleted hydrocarbon reservoirs and aquifer reservoirs, which comprises the vast majority of storage fields including Aliso Canyon and all the other California storage fields. API RP 1170 addresses storage in salt caverns.
Don Santa, CEO of the Interstate Natural Gas Association of America (INGAA), said aspects of the task force’s recommendations – beyond industry adoption of 1170/1171 –are problematic in addition to being generally premature because they were issued prior to the completion of the root-cause analysis of the Aliso Canyon storage incident. That is being done by the California Public Utilities Commission (CPUC) through a third-party contractor.
INGAA is particularly concerned about one recommendation. “We also are concerned by the task force’s recommendation that storage wells with single barriers be transitioned to double barriers,” Santa stated. “As written, this prescriptive recommendation could affect the majority of U.S. natural gas storage wells, and adversely affect customer service and reliability. Installing double barriers is not the only approach to improve gas storage safety.”
The report states that underground gas storage wells should be designed so that a single point of failure cannot lead to leakage and uncontrolled flow. Operators who have existing wells with single-point-of-failure designs should have a risk management plan to maintain safe well operating pressure that includes a rigorous monitoring program, well integrity evaluation, leakage surveys, mechanical integrity tests, conservative assessment intervals, and in most cases, a plan to phase out these designs. An operator seeking to continue utilizing a single-barrier well design should prepare and make available for regulatory review during inspections a rigorous and fully documented engineering analysis of the design that considers the potential impacts and consequences of a leak at any point for each well without benefit of a double barrier. The recommendation does imply that wells with single barrier systems may be kept if certain steps are taken.
Cathy Landry, INGAA spokeswoman, stated, “We are concerned with how the terms ‘single barrier’ and ‘double barrier’ will be defined. We disagree with the suggestion that all storage wells injecting/withdrawing through production casing – a possible interpretation of single barrier – have a ‘problem’ that needs to be addressed. A significant majority of gas storage wells in the U.S. operate in this manner, and as the interagency report repeatedly points out, storage incidents are rare.”
The PIPES Act requires a final rule to be published by the summer of 2018. Of course, PHMSA has missed congressional deadlines for numerous rulemakings over the past decade, leading some states to step in on their own with California prominent among them. The PIPES Act also provides that states can adopt additional or more stringent safety regulations as long as they are compatible with the federal minimum standards.
PHMSA expands mandate to install excess flow valves
It has been decades in the making, but PHMSA announced expanded requirements for local gas distributors regarding installation of excess flow valves (EFVs). The American Gas Association (AGA) and other local gas suppliers have long supported the widened mandate.
The AGA in October 2011 issued a “Commitment to Enhancing Safety” which includes a commitment by AGA member companies to expand the installation of EFVs to new and fully replaced branch services, small multi-family facilities, and small commercial facilities where economically, technically and operationally feasible. Based on an informal survey taken by AGA, this commitment has resulted in EFVs being installed on over 95 percent of all new and replaced services since June 30, 2013.
The final rule PHMSA issued in October adds four new categories of service for which EFV installation will be required. These categories are for new and entirely replaced services. The existing EFV installation requirement for single family residences (SFRs) served by a single service line remains unchanged. The new categories of service are as follows:
Branched service lines to an SFR installed concurrently with the primary SFR service line (a single EFV may be installed to protect both lines).
Branched service lines to an SFR installed off a previously installed SFR service line that does not contain an EFV.
Multifamily installations, including duplexes, triplexes, fourplexes and other small multifamily buildings (e.g., apartments, condominiums) with known customer loads at time of service installation, based on installed meter capacity, up to 1,000 standard cubic feet per hour (SCFH) per service.
A single, small commercial customer served by a single service line with a known customer load at time of service installation, based on installed meter capacity, of up to 1,000 SCFH per service.
In addition, the final rule requires curb valves, or EFVs, if appropriate, for applications operating above 1,000 SCFH. Curb valves cannot be operated instantaneously like EFVs; they are manual. This was probably the most controversial aspect of the final rule, given that the local distribution industry was solidly behind expansion of the EFV mandate. With regard to curb valves, distribution companies objected to early wording that would have given first responders automatic access to those valves. The operators said it ought to be up to their discretion as to who gets access to curb valves.
The National Transportation Safety Board (NTSB) recommended installing EFVs on all homes and buildings in 2001 after its investigation of a 1998 explosion in Virginia. PHMSA eventually mandated EFVs on SFRs in 2009 and then began considering widening that requirement, which became somewhat of a necessity when Congress gave the agency a kick in the pants via an amendment to the Pipeline Safety, Regulatory Certainty, and Job Creation Act of 2011.
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