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A Pragmatic Approach to PHMSA’s IFR and
Risk Assessment
Chris Foley
Vice President
Underground Natural Gas Storage
1. Historical Perspective of Storage Incidents
2. New PHMSA IFR Requirements
3. Risk Analysis Potential Pit Falls
4. Building Blocks For Compliance With IFR
• Gap Analysis
• Process Development and Improvement
• Risk Analysis
• Integrity Assessment/Tracking
• Remediation
Overview
October 2015-February 2016Porter Ranch
CA, Aliso Canyon Natural
Gas reservoir gas leak
April 1992Brenham TX, salt cavern
HVL release & explosion
July 1997PHMSA
Advisory Bulletin 97-04; Underground
Storage of Natural Gas or
Hazardous Liquids
August 2004Moss Bluff TX,
natural gas storage cavern uncontrolled release and
fire
February 1995IOGCC, Natural Gas Storage in Salt Caverns, A guide for state
regulators.
January 2001Hutchinson
KS, natural gas salt cavern
leak and explosions
October 2006Fort Morgan CO, natural gas storage
reservoir leak
September 2015API RP 1171 Functional Integrity of Natural Gas Storage in Depleted
Hydrocarbon Reservoirs and
Aquifer Reservoirs
October 2016Interagency Task Force on Natural
Gas Storage Safety: Final
Report, Ensuring Safe & Reliable Underground Natural Gas
Storage
June 2016PIPES Act 2016,
Section 12 Underground gas storage
facilities
July 2015API RP 1170 Design and
operation of Solution-mined
Salt Caverns Used for
Natural Gas Storage
February 2016PHMSA
Advisory Bulletin 2016-
02, Safe Operation of Underground
Storage Facilities for Natural Gas
July 2016CA DOGGR
Draft Article 4. Requirements
for Underground Gas Storage
Projects
December 2016PHMSA Interim
Final Rule; Safety of Underground
Natural Gas Storage Facilities
1. Can’t See the Forest For The Trees Syndrome -
• you might not realize that a branch of separate trees go together to make a forest
2. Draining the Swamp Syndrome –
• drain the swamp means to exterminate something that is harmful (in this case risk)
3. Trust But Verify Syndrome –
• extensive verification procedures that would enable both sides to monitor compliance with the treaty
Potential Pitfalls
1. Types of Models
2. Critical Issues and Drivers
3. How much do we know and how well do we know it?
4. Feeding the beast
Building a Risk Model – What’s the Objective?
PHMSA IFR – Building Blocks for Compliance
1. Standards or Procedures
• Shall – (125)
• Should – (250+)
• May – (50+)
2. Storage Integrity Plan
• Overarching Plan – focus on “how to”
3. Risk Management Plan
• Describes how you will assess and manage risk
Gap Analysis
Process Development and Improvement
• Storage Risk Management Plan• Site-Specific Operations & Integrity Standards
1. Wells (subsurface)
• Challenging to Asses Integrity but well Developed Technology is Available
2. Reservoir (facility)
• Most Challenging to Assess Integrity but Combination of Technology and Industry Accepted Methods
3. Surface (Wellhead and near wellhead piping)
• Relatively easy to assess – can see, touch, and measure directly
Risk Model Category Elements
1. Threats
• Grouped According to Elements listed in Table 1 of API 1171
• Include concerns which can be assessed with existing methods, tools, and technology
• Site-specific issues
2. Consequences
• Comprehensive list outlined in API 1171
• Challenge is how to characterize continuum of outcomes
3. Threats and Consequences
• Should be weighted to differentiate potential impacts
Threats and Consequences
1. Relative Ranking
• Allows Prioritization of P&M Measures
• Wells – Well Specific
• Reservoir – Facility Basis
• Surface – Well Specific
2. Consequences
• Comprehensive list outlined in API 1171
• Challenge is how to characterize continuum of outcomes
Output Yields a Risk Score
Graphical Output
1. 3-8 Years to Complete Process
• Baseline Assessments – Size Dependent
• Existing Baseline Assessments May be Used*
• Periodic Review and Update of Risk Assessment
• Ongoing Review of Standards
2. Plan will likely Evolve
• New Information will alter initial priorities
Integrity Assessment and Tracking
1. 3-8 Years to Complete Process
• Baseline Assessments – Size Dependent
• Existing Baseline Assessments May be Used*
• Periodic Review and Update of Risk Assessment
• Ongoing Review of Standards
2. Auditable Process
• Close Out of Remediation Efforts
• Record Keeping
• Training
Remediation Progress Tracking
