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Building off of President Trump’s “Made in America” campaign commitment, the Trump Administration issued a tariff on steel imports on March 8, 2018. The proclamation finds that the imposition of duties on steel articles is necessary to ensure that steel imports will not threaten national security and, effective March 23, 2018, steel imports will be…

On October 19, 2017, the Pipeline and Hazardous Materials Safety Administration (PHMSA) announced an additional comment period on its December 19, 2016 interim final rule (IFR) which established minimum federal safety standards for underground natural gas storage facilities.  PHMSA will accept comments until November 20, 2017.  This notice comes amidst the current administration’s executive orders on deregulation and a recent DOT request for comment on regulatory reform.
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Continue Reading Underground Natural Gas Storage IFR Comment Period Reopened

On December 19, 2016, PHMSA issued an interim final rule (IFR) to establish for the first time  minimum federal safety standards for underground natural gas storage facilities.  The rule was issued in response to the 2015 Aliso Canyon storage leak that lasted almost four months,  and a subsequent Congressional mandate to issue federal standards for underground storage.  Among other things, the IFR incorporated by reference (thereby making them mandatory) two American Petroleum Institute (API) Recommended Practices (RPs) regarding underground natural gas storage in salt caverns and reservoirs: (1) API RP 1170, “Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage,” (July 2015); and (2) API RP 1171, “Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs,” (Sept. 2015).  API finalized both of those RPs in response to the Aliso Canyon incident.
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Continue Reading PHMSA to Reassess Underground Natural Gas Storage Rule

Last December, PHMSA issued an interim final rule (IFR) to establish—for the first time ever—minimum federal standards for underground natural gas storage facilities.  The IFR imposes significant new requirements in a short timeframe for “downhole facilities,” including wells, wellbore tubing and casings at underground natural gas storage facilities.  Those rules became effective in late January and most recently, PHMSA finalized user fees to fund a training program for inspectors with oversight of underground storage facilities and other guidance materials.  While PHMSA moves forward in regulating these facilities, the State of Texas, INGAA, and AGA have challenged the rule and commenters have criticized the rule as rushed, poorly drafted, and unrealistic.
Continue Reading Underground Natural Gas Storage: Regulations and Fees Move Forward Despite Appeal and Criticism