Changes to the regulatory landscape, new requirements around record-keeping practices and an increased emphasis on safety are leading underground gas storage operators to transform their operations from day-to-day activities and compliance focus to asset management driven by risk assessment and prioritization. Emerging regulations are forcing this shift from a reactive compliance driven approach to a proactive asset risk and integrity management strategy.
Historically, the lack of federal rules for gas storage operators resulted in limited or state-specific rules for operators. In the aftermath of the 2015 Aliso Canyon natural gas storage well leak in California, the Pipeline and Hazardous Materials Safety Administration (PHMSA) moved rapidly to adopt industry standards that were already defined with operator inputs. While the requirements were not necessarily new, the mandate and implementation timeline were strictly enforced.
As underground natural gas storage operators begin to review their operating, maintenance, and emergency response activities to ensure that the integrity of their facilities are properly maintained, the report outlines key asset risk and integrity management initiatives that can help enable operators to strategically align to these new regulatory requirements.
To support the execution of these initiatives, PwC has an integrity management framework shown here that has been used by utilities for distribution and transmission asset management. PwC’s Integrity Management Framework focuses on a “closed-loop” integrity management (IM), as well as critical enablers to help facilitate traceability and quality. This framework can provide gas storage operators with a high-level systematic approach for managing their assets.