Recently, PHMSA released an advisory bulletin outlining how operations of underground storage facilities for natural gas should be reviewed and maintained, as well as how integrity management programs surrounding these facilities should be developed, implemented and updated. This is significant since PHMSA has not regulated this in the past, and the last similar bulletin was posted in 1997, which left regulationof gas storage facilities up to the states.
We’ve pulled together some of the primary bullet points of PHMSA’s bulletin for you to review here in this blog post.
When it comes to maintaining the storage facilities, the below actions should be reviewed and updated on an annual basis. Operators should review and update their operating and maintenance (O & M) processes and procedures to include:
- Operational limits
- Data collection and integration
- Risk assessments
- Mitigation measures
- Record keeping
PHMSA advises the below actions be taken when developing, implementing and updating safety and integrity programs.
- Document and ensure the design of pressure limits are not exceeded during injection activities
- Monitor all wells for the presence of annular gas or liquids
- Inspect the wellhead assembly and attached pipelines on a periodic basis
- Conduct periodic functional tests of all surface and subsurface safety valve systems and wellhead pipeline isolation valves for proper function and ability
- Evaluate subsurface safety valves and perform risk assessments in accordance with API RP 1171 criteria
- Perform assessments to verify and demonstrate mechanical integrity of wells, piping and equipment
- Implement a detailed corrosion monitoring and integrity evaluation program
- Implement procedures to evaluate well and storage facilities
- Identify potential threats and hazards associated with operation of an underground storage facility
- Use appropriate monitoring techniques to identify integrity changes
- Develop emergency procedures that should be reviewed, conducted and updated on an annual basis
- Maintain records for the life of a storage well
To view the PHMSA advisory bulletin in full, click here. Are you having trouble wrapping your head around all this and want an expert opinion? Our integrity and compliance experts can assist you with developing or enhancing your integrity management program to meet the gas storage requirements; as well as O & M and emergency response procedures.