PHMSA Issues Limited Enforcement Discretion for UNGS

PHMSA has issued a Notice of Limited Enforcement Discretion for its Direct Final Rule (DFR) published in July of this year. The DFR required operators to adopt the second editions of API RP 1170, Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage, and API RP 1171, Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs. Updates were due to be made in two weeks, on January 1, 2026.

After the DFR was published two associations, AGA and INGAA, filed a request for a stay of enforcement until January 1, 2027 to allow operators time to implement updated policies and procedures. PHMSA granted the stay of enforcement recommending its state partners exercise the same. However, nothing prohibits PHMSA from pursuing enforcement action if it determines that a significant safety issue exists.

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