States First Comments on PHMSA Rule

OKLAHOMA CITY, OK – The States First Initiative has sent comments directly to the US Pipeline and Hazardous Materials Safety Administration (PHMSA) Administrator Marie Therese Dominguez in regards to the interim final rule (IFR) that was issued on December 14, 2016.

The IFR aims to revise the Federal pipeline safety regulations to address critical safety issues at underground natural gas storage facilities.  

The States First letter included detailed comments on API's Recommended Practices (RP's) 1170 and 1171, which are incorporated in the IFR. 

"First, we highlight for PHMSA both gaps in the coverage of the Recommended Practices with respect to key issues for regulating the lifecycle and full scope of gas storage projects," said in the letter. "Recommended Practices would be difficult for PHMSA to implement as a regulation – for example, because of vagueness, ambiguity, or insufficient detail."

The letter is signed by the States First Intiative's Underground Gas Storage Work Group co-chairs Harold R. Fitch, Chief of the Office of Oil, Gas and Minerals at the Michigan Department of Environmental Quality, and Richard J. Simmers, Chief of the Division of Oil and Gas Resources Management at the Ohio Department of Natural Resources.

The Underground Gas Storage Work Group (UGSWG), that was formed in early 2016, has been working diligently on a report that will provide considerations to state regulatory agencies for underground gas storage facitlities. Within this working group, they have carefully reviewed API's RP's that are included in the PHMSA IFR. 

"While the RP’s contain substantial information and guidance regarding underground storage, it is our belief that they require considerable wording revisions and additions to make them effective as regulation," the comments state. 

PHMSA will be posting this IFR on the Federal Register soon. Comments will be accepted for 60 days from the day it appears. 

The UGSWG is expected to finalize its report early next year and will be published on the IOGCC, GWPC and States First Initiative web sites. 

Letter to the Administrator

Comments on the PHMSA IFR as it relates to underground gas storage facilities