NATURAL GAS 

STORAGE

Department of 

Transportation Could 

Take Additional Steps 

to Improve Safety 

Enforcement Planning

Report to Congressional Requesters

November 2017

GAO-18-89

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-18-89, a report to 

congressional requesters

November 2017

NATURAL GAS STORAGE

Department of Transportation Could Take Additional 

Steps to Improve Safety Enforcement Planning

What GAO Found

To meet its requirement under the Protecting Our Infrastructure of Pipelines and 

Enhancing Safety (PIPES) Act of 2016, the Department of Transportation’s 

(DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) issued 

minimum safety standards in an interim rule and plans to finalize them by 

January 2018. Under the interim standards, site operators are to follow industrydeveloped best practices to detect and prevent leaks and plan for emergencies, 

among other things. Since the interim rule went into effect in January 2017, the 

minimum safety standards apply to all 415 natural gas storage sites, and the rule 

will be subject to further revision before it is final.

To enforce its safety standards, PHMSA has taken steps to establish a natural 

gas storage safety enforcement program. For example, PHMSA has started 

developing a training program for its inspectors. PHMSA also has identified a 

strategic goal for its program—to promote continuous improvement in safety 

performance—and is developing a performance goal for its training program. 

However, PHMSA has not yet followed certain leading strategic planning

practices. For example, PHMSA has not yet defined the level of performance to 

be achieved, fully addressed all core program activities, or used baseline data to 

develop its performance goal. GAO has previously reported that requirements 

under the Government Performance and Results Act (GPRA) and GPRA 

Modernization Act of 2010—which include establishing performance goals to 

define the level of performance—can serve as leading practices for lower levels 

of an agency, such as PHMSA. GAO also has found that successful 

performance goals address all core program activities. PHMSA’s goal focuses on 

training and does not address other core program activities, such as conducting 

effective inspections. For example, a goal to evaluate whether PHMSA’s 

inspections are effective could be to annually reduce, by a certain percentage, 

the number of sites not meeting minimum standards. PHMSA officials told GAO 

that they will strive to add and refine performance goals as the program evolves. 

As they do so, ensuring that these goals define the level of performance, 

address all core program activities, and use baseline data could help PHMSA 

better track progress toward its strategic goal.

Approximate Location of Natural Gas Storage Sites within Counties Populated by 100,000 or 

More People

View GAO-18-89. For more information, 

contact Alfredo Gómez at (202) 512-3841 or 

gomezj@gao.gov; or Frank Rusco at (202) 

512-3841 or ruscof@gao.gov

Why GAO Did This Study

Natural gas storage is important for 

ensuring that natural gas is available 

when demand increases. There are 

415 storage sites—including 

underground caverns and depleted 

aquifers and oil and gas reservoirs—

located in 31 states, often near 

population centers (see fig.). Leaks 

from these sites, such as one near Los 

Angeles that led to the temporary 

relocation of about 8,000 families in 

2015, can result in environmental and 

economic damage. Until 2016, states 

set standards for 211 sites, but there 

were no standards for 204 sites 

connected to interstate pipelines 

subject to federal jurisdiction. With 

passage of the PIPES Act of 2016, 

PHMSA, an agency within DOT that 

sets and enforces standards for energy 

pipelines, among other things, was 

tasked with issuing minimum standards 

for all gas storage sites. 

GAO was asked to review natural gas 

storage safety standards. This report 

examines (1) PHMSA’s efforts to 

implement the requirement to issue 

minimum safety standards for natural 

gas storage sites and (2) the extent to 

which PHMSA has planned 

strategically to enforce its safety 

standards for these sites. GAO 

reviewed PHMSA documents and 

plans, compared them to leading 

planning practices, and interviewed 

PHMSA officials.

What GAO Recommends

GAO is making two recommendations, 

which are that PHMSA (1) define levels 

of performance and address all core 

program activities and (2) use budget 

data to refine performance goals for its 

gas storage program. DOT concurred 

with GAO’s recommendations.
Page i GAO-18-89 Natural Gas Storage Safety

Letter 1

Background 3

PHMSA Has Issued Interim Safety Standards and Plans to 

Finalize Them by January 2018 11

PHMSA Has Taken Steps to Establish an Enforcement Program 

but Has Not Yet Followed Certain Leading Practices of 

Strategic Planning 17

Conclusions 27

Recommendations for Executive Action 27

Agency Comments 28

Appendix I Objectives, Scope, and Methodology 30

Appendix II Number of Active Natural Gas Storage Sites as of January 2016 by 

State and Jurisdiction 33

Appendix III Comments from the Department of Transportation 37

Appendix IV GAO Contacts and Staff Acknowledgments 39

Tables

Table 1: Timeline of Key Events in the Development of the 

Pipeline and Hazardous Materials Safety Administration’s 

(PHMSA) Minimum Standards for Natural Gas Storage 

Safety 15

Table 2: Excerpt From the Department of the Treasury’s Fiscal 

Year 1999 Annual Performance Plan Featuring the 

Internal Revenue Service 24

Table 3: Number of Active Natural Gas Storage Sites, by State 

and Jurisdiction, as of January 2016 34

Contents
Page ii GAO-18-89 Natural Gas Storage Safety

Figures

Figure 1: Major Types of Geologic Formations where Natural Gas 

Storage Sites Are Located 4

Figure 2: Approximate Location of Natural Gas Storage Sites 

within Counties Populated by 100,000 or More People 5

Figure 3: Total Budgetary Resources Available for the Pipeline 

and Hazardous Materials Safety Administration’s 

(PHMSA) Pipeline Safety Program, Fiscal Years 2007–

2016 26

Abbreviations

API American Petroleum Institute

BLM Bureau of Land Management

DOE U.S. Department of Energy

DOT U.S. Department of Transportation

EIA Energy Information Administration

EPA U.S. Environmental Protection Agency

FERC Federal Energy Regulatory Commission

GPRA Government Performance and Results Act of 1993

IRS Internal Revenue Service

OMB Office of Management and Budget

PHMSA Pipeline and Hazardous Materials Safety 

 Administration 

PIPES Act Protecting Our Infrastructure of Pipelines and 

 Enhancing Safety Act of 2016

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately.
Page 1 GAO-18-89 Natural Gas Storage Safety

441 G St. N.W.

Washington, DC 20548

November 22, 2017

Congressional Requesters

Natural gas storage sites are key elements in our nation’s energy system, 

helping ensure that natural gas, which is used for a range of applications 

such as heating homes and as a fuel to produce electricity, is available 

when demand peaks.1 There are 415 active natural gas storage sites 

located in 31 states. These sites store natural gas in underground 

geologic formations such as caverns, depleted aquifers, and depleted oil 

and gas reservoirs.

Major leaks from these sites can result in serious economic disruption 

and environmental damage. Natural gas leaks can cause explosions or 

fires and, according to the Environmental Protection Agency (EPA), 

natural gas is considered to be a significant greenhouse gas which, if 

released, can pose significant environmental harm. One such leak 

occurred in 2015 at the Aliso Canyon Underground Storage Facility near 

the neighborhood of Porter Ranch in suburban Los Angeles, California. 

This leak released 5.4 billion cubic feet of natural gas into the atmosphere 

over the course of almost 4 months, which caused the temporary 

relocation of more than 8,000 families. In addition, the accident disrupted 

the ability of the Aliso Canyon site to deliver stored gas to electrical power 

plants, which in turn posed risks to the stability of California’s electrical 

grid. Like the Aliso Canyon facility, many of the nation’s natural gas 

storage sites are located within 3 miles of a city, town, or other populated 

area, according to the Department of Energy (DOE).

Until 2016, states had sole responsibility for overseeing the safety of the 

intrastate natural gas storage sites within their states, but states’ safety 

standards for these sites varied and applied only to the intrastate sites 

that were wholly within their borders. In contrast, interstate natural gas 

storage sites were not covered by state regulations.2 These interstate 

sites are subject to state and local permitting and federal licensing 

requirements, but they were not regulated for safety. Existing Department 

 1

For the purposes of this report, the term “natural gas storage” refers to underground 

natural gas storage, which uses geological formations to store natural gas by injecting gas 

under high pressure. 

2

A site is considered to be interstate if the site is linked to a federally-regulated interstate 

pipeline. 

Letter
Page 2 GAO-18-89 Natural Gas Storage Safety

of Transportation (DOT) safety regulations, which had been in place for 

more than 30 years, applied to conventional surface pipelines and aboveground equipment at all natural gas storage sites. However, these 

existing regulations did not apply to the underground portions of the sites, 

such as wells, wellbore tubing, and casing. In June 2016, the Protecting 

Our Infrastructure of Pipelines and Enhancing Safety (PIPES) Act of 2016 

directed DOT to develop and issue minimum safety standards for all 

natural gas storage sites.3 DOT’s Pipeline and Hazardous Materials 

Safety Administration (PHMSA) develops and enforces these standards.

You asked us to review the development and enforcement of natural gas 

storage safety standards. This report examines (1) the status of PHMSA’s 

efforts to implement the requirement under the PIPES Act to issue 

minimum safety standards for natural gas storage sites and (2) the extent 

to which PHMSA has planned strategically to enforce its safety standards 

for natural gas storage sites.

To examine the status of PHMSA’s efforts to implement the requirement 

under the PIPES Act to issue minimum safety standards for natural gas 

storage sites, we interviewed agency officials and examined laws, 

regulations, and agency documents that describe the authority, time 

frames, and enforcement goals for implementing new federal standards 

under the PIPES Act. To examine the extent to which PHMSA has 

planned strategically to enforce its safety standards for natural gas 

storage sites, we examined PHMSA’s policies, guidance, and plans and 

interviewed agency officials about their plans for oversight. We compared 

PHMSA’s plans with leading practices for strategic planning identified by 

our prior work. Strategic planning is a systematic process for defining 

desired outcomes and translating this vision into goals and steps to 

achieve them. For more information on our objectives, scope, and 

methodology, see appendix I.

We conducted this performance audit from November 2016 to November 

2017 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

 3

Pub. L. No. 114-183, § 12 (2016). 
Page 3 GAO-18-89 Natural Gas Storage Safety

This section discusses the purpose, types, and locations of natural gas 

storage sites; leaks from such sites; safety enforcement prior to 2017; 

and the PIPES Act.

Natural gas storage sites—geologic formations where natural gas is 

stored deep underground and retrieved for later use—are key parts of our 

energy system. Natural gas provides about 30 percent of U.S. energy 

needs, is used to generate a third of the nation’s electricity, is widely used 

for heating homes and businesses, and is used in a variety of industrial 

processes, according to Energy Information Administration (EIA) 

information. Natural gas storage sites provide a way to meet peak energy 

needs—such as during a cold spell in the winter or during periods of high 

electricity demand in the summer—more quickly than would be possible if 

relying solely on pipelines that transport natural gas from distant 

production fields. Natural gas storage sites are privately owned and 

operated by a variety of companies in the energy industry, including local 

utilities, independent companies that store gas for sale at peak times to 

other companies, and interstate pipeline companies.

There are three major types of underground geologic formations where 

natural gas storage sites are found: (1) underground salt caverns, 

(2) depleted aquifers, and (3) depleted oil and gas reservoirs.4 The wells 

that inject or withdraw natural gas from the underground formations can 

extend thousands of feet underground. The 415 natural gas storage sites 

in the United States contain about 17,000 wells, ranging from a few wells 

per site to over a hundred wells at some larger sites. Figure 1 illustrates 

the types of geologic formations where natural gas storage sites are 

constructed and operated.

 

4

According to EIA, the most commonly used underground storage sites are depleted oil 

and natural gas reservoirs, which are widely available; depleted aquifers are also widely 

available but are often more expensive to develop than depleted oil and gas fields. 

Storage operators can also store natural gas in abandoned mines and hard rock caverns. 

Background

Purpose, Types, and 

Locations of Natural Gas 

Storage Sites
Page 4 GAO-18-89 Natural Gas Storage Safety

Figure 1: Major Types of Geologic Formations where Natural Gas Storage Sites Are 

Located

Natural gas storage sites are found in 31 states across the country, 

according to EIA data. Over 300 cities, towns, and other populated areas 

are located near a natural gas storage site, according to a DOE analysis. 

Operators often locate natural gas storage sites near major population 

centers or large gas pipelines to improve their ability to deliver natural gas 

when needed. Figure 2 shows the approximate location of natural gas 

storage sites located within counties populated by 100,000 or more 

people.
Page 5 GAO-18-89 Natural Gas Storage Safety

Figure 2: Approximate Location of Natural Gas Storage Sites within Counties Populated by 100,000 or More People

Note: The circles on the map represent the approximate locations of natural gas storage sites based 

on the centers of the counties; they do not represent their exact size and boundaries. Alaska is not 

shown because the sites there are not within counties of 100,000 people or more, and Hawaii does 

not appear because it has no natural gas storage sites.

Leaks from natural gas storage sites can be caused by a variety of 

factors—such as underground fissures or inadequately designed or 

damaged wells—and have the potential to affect human health, cause 

economic disruption, and harm the environment. For example, natural 

gas poses the risk of explosion and asphyxiation within enclosed spaces. 

In addition, other components of natural gas can cause short-term 

neurological, gastrointestinal, and respiratory symptoms, according to the 

Los Angeles County Department of Public Health.5 Moreover, if a large 

 5

Los Angeles County Department of Public Health, Interim Director, Aliso Canyon Gas 

Leak Incident and Potential Public Health Implications, Memorandum to the Los Angeles 

County Board of Supervisors (Los Angeles, Calif.: Dec. 1, 2015). 

Leaks from Natural Gas 

Storage Sites
Page 6 GAO-18-89 Natural Gas Storage Safety

gas storage facility unexpectedly goes offline due to a major leak, it can 

disrupt the natural gas supply system, which in turn may affect the flow of 

gas to heat homes and businesses or may cause electrical blackouts due 

to the loss of fuel for gas-fired electrical generators. According to a DOE 

report,6 the natural gas stored in geologic formations is under high 

pressure and may find its way to the surface if underground fissures or 

unplugged oil and gas wells allow the geologic formation to be breached. 

Leaks can also occur if the wells used to inject and withdraw natural gas 

from geologic formations lose integrity due to cracking of cement used to 

seal the well or other factors. Older wells used for natural gas storage 

were often drilled for other reasons, such as oil and gas production, and 

are more likely to have age-related degradation, according to DOE. About 

half of the about 17,000 wells that inject and withdraw natural gas from 

storage sites are more than 50 years old, and many wells are more than 

100 years old, according to DOE. In addition, DOE reported that other 

factors may contribute to leaks, such as earthquake activity, nearby 

drilling activity, or other mechanical stresses and undetected corrosion 

that may not be known by the natural gas storage site operators. Further, 

DOE has reported that operators can sustain safety by regularly 

maintaining site equipment, monitoring and repairing leaks, keeping 

records about the site, and planning for possible emergencies, among 

other things.

Leaks from natural gas storage sites can result in significant and harmful 

effects on public health and safety, the environment, and the energy 

system. DOE, PHMSA, and others have identified three major leaks from 

natural gas storage sites since 2000 that illustrate these potential 

negative effects:

• The Aliso Canyon leak, which was detected in October 2015 and 

continued for nearly 4 months, focused national attention on natural 

gas storage safety. As of August 2017, the cause of the leak had not 

been conclusively determined. However, the leak occurred in a well 

that, at the time, was about 60 years old, according to DOE.7 The 

 6

U.S. Department of Energy, Ensuring Safe and Reliable Underground Natural Gas 

Storage: Final Report of the Interagency Task Force on Natural Gas Storage Safety

(Washington, D.C.: Oct. 24, 2016). 

7

The operator had performed a “workover” operation on the well about 40 years ago. 

Workovers refer to one or more operations that may involve cleaning out sand from a well, 

repairing the piping in a well, and other activities, often to increase the productivity of the 

well. 
Page 7 GAO-18-89 Natural Gas Storage Safety

operator of the Aliso Canyon site unsuccessfully attempted to stop the 

leak several times over the 4-month event and eventually was able to 

do so in February 2016 by permanently sealing the well. According to 

the private operator, it temporarily relocated about 8,000 neighboring 

families until the leak was abated. Also, the leak disrupted the Aliso 

Canyon site’s ability to supply natural gas to electricity generating 

plants. Because the Aliso Canyon site supplies gas for nearly 10 

gigawatts of electricity in the Los Angeles basin, the leak led to 

concerns that there may not be enough gas to serve the electricity 

needs of the surrounding region during peak times. In July 2017, 

California state regulators announced that the operator had conducted 

a comprehensive safety review and that the regulators would allow 

Aliso Canyon to reopen at a greatly reduced capacity in order to 

prevent energy shortages.

• In August 2004, the Moss Bluff natural gas storage site in Liberty 

County, Texas, experienced a major leak due to a damaged well. The 

leaking gas caught fire and burned for over 6 days, according to DOE 

and PHMSA documents. As a result, the gas was released into the 

atmosphere as carbon dioxide, which, according to an EPA analysis, 

is a less potent greenhouse gas than natural gas, which was released 

by the Aliso Canyon leak.

• In January 2001, the Yaggy natural gas storage site leaked through 

underground fissures from the site’s salt caverns into the nearby city 

of Hutchinson, Kansas, eventually causing an explosion in the city’s 

downtown business district, DOE reported. Two people were killed, 

and several businesses were damaged or destroyed by the explosion.

Before 2017, many natural gas storage sites were subject to varied, stateby-state safety enforcement. States were responsible for regulating and 

enforcing safety at sites that were located solely within their boundaries 

and only linked to pipelines within the state. Agencies representing 

26 state governments licensed 211 such sites, which amounted to about 

half of the 415 active sites in the United States. Prior to 2017, these state 

governments applied various safety standards that addressed 

underground conditions, such as the integrity of the geologic formations 

that store natural gas, or the construction and maintenance of wells that 

inject and withdraw gas. For example, according to a DOE report,8 some 

states’ standards specified how site operators should safely construct the 

 8

U.S. Department of Energy, Ensuring Safe and Reliable Underground Natural Gas 

Storage: Final Report of the Interagency Task Force on Natural Gas Storage Safety. 

Safety Enforcement for 

Natural Gas Storage Sites 

Prior to 2017
Page 8 GAO-18-89 Natural Gas Storage Safety

wells. Other states’ standards specified how wells were to be maintained 

during their useful life, or how they were to be safely plugged and 

abandoned after their useful life ended.

Prior to 2017, the remaining 204 interstate natural gas storage sites were 

subject solely to federal oversight. However, the federal government had 

not issued safety standards for them. The Federal Energy Regulatory 

Commission (FERC) licenses storage sites that serve the interstate 

natural gas market—a market regulated by FERC. However, according to 

FERC, its licensing process focuses on whether a proposed site serves 

an economic need, and it does not review the safety conditions of a site 

when reviewing whether to grant a license. In this role, FERC has 

licensed 204 sites in 24 states. As part of its mission to ensure the safety 

of the interstate natural gas pipeline system—of which natural gas 

storage sites are a part—PHMSA had the regulatory authority to issue 

and enforce safety standards for interstate natural gas storage sites. 

However, PHMSA’s interstate pipeline safety regulations did not extend to 

underground natural gas storage facilities, even when connected to 

interstate pipelines. Moreover, because interstate sites were under 

federal jurisdiction, state safety standards could not be applied to such 

sites.9

Other federal agencies had responsibilities that addressed limited aspects 

of safety at natural gas storage sites. DOE provided technical assistance 

to California during the Aliso Canyon incident, and has researched the 

effects of natural gas storage leaks on the reliability of the electricity grid. 

The Bureau of Land Management (BLM), within the Department of the 

Interior, manages public lands that overlap, either partially or fully, with 

33 natural gas storage sites.10 EPA provides funding and oversight to 

help states and local pollution control agencies meet their responsibility to 

monitor air quality within their jurisdictions, according to EPA officials. 

EPA can also provide its expertise and support to states and local 

communities in the event of natural gas storage leaks, as it did during the 

leak at Aliso Canyon. However, EPA does not regulate underground 

conditions at gas storage sites.

 9

See Colo. Interstate Gas Co. v. Wright, 707 F. Supp. 2d 1169 (April 13, 2010). 

10PHMSA officials stated that storage sites on BLM land are subject to the new PIPES Act 

standards. 
Page 9 GAO-18-89 Natural Gas Storage Safety

In June 2016, Congress passed and the President signed the PIPES Act, 

which, among other things, directed DOT to establish minimum safety 

standards for all natural gas storage sites by June 2018 after considering 

recommendations from a federal task force and industry standards. 

PHMSA sets and enforces these standards. 

The PIPES Act also directed DOE to establish and lead the task force,11

which was charged with analyzing the Aliso Canyon incident and making 

recommendations to reduce the occurrence of similar incidents in the 

future. The task force published its report in October 2016.12 The report 

included findings in three areas—well integrity, environmental and health 

protection, and energy reliability. The report also made 

44 recommendations to enhance natural gas storage safety, including 3 

key recommendations:

• Operators of natural gas storage sites should make advance 

preparations with appropriate federal, state, and local governments to 

mitigate potential future leaks.

• Electrical grid operators should prepare for the risks that potential gas 

storage disruptions create for the electric system.

• Operators of natural gas storage sites should begin a rigorous 

program to evaluate the status of the wells, establish risk 

management planning, and, in most cases, phase out old wells with 

single-point-of-failure designs.

The PIPES Act directed DOT to consider industry consensus standards to 

the extent practicable in establishing its minimum safety standards. 

Consensus standards for the oil and gas industry—including those for 

natural gas storage—are issued by various entities, including the 

American Petroleum Institute (API). API consensus standards describe 

how to safely perform technical procedures, such as drilling wells for oil 

and gas production, refining produced natural gas into usable gas for 

 

11In April 2016, DOE and PHMSA formed a task force to examine the Aliso Canyon 

incident and to develop recommendations on how similar incidents could be prevented in 

the future. The PIPES Act formalized the task force by statute. 

12U.S. Department of Energy, Ensuring Safe and Reliable Underground Natural Gas 

Storage: Final Report of the Interagency Task Force on Natural Gas Storage Safety. The 

task force also reported that the cause of the leak had not yet been conclusively 

determined. A separate technical root cause analysis is being conducted under the 

direction of California state regulators, and was ongoing as of August 2017, according to 

PHMSA officials. 

The PIPES Act
Page 10 GAO-18-89 Natural Gas Storage Safety

heating and electricity generation, and conducting “workover” operations 

to refurbish existing wells. API develops its consensus standards 

involving industry, manufacturers, engineering firms, the public, 

academia, and government, and API’s recommended practices are 

frequently adopted by a majority of the industry, according to API and 

PHMSA. Following several years of study and discussion by industry 

experts and government officials, including participation by PHMSA, API 

issued two documents outlining recommended practices for the 

development and operations of natural gas storage sites.13 These 

recommended practices describe the procedures for designing, locating, 

constructing, and operating natural gas storage sites, and include such 

activities as inspecting and testing the wells used to inject and withdraw 

gas from natural gas storage sites and monitoring the integrity of the 

underground formations where natural gas is stored. The API documents 

also recommend that operators prepare for emergencies and train the 

personnel who operate the sites.

Under the PIPES Act, state governments also have a continuing role in 

enforcing natural gas storage safety for the sites in their states. The act 

allows states to certify with PHMSA that they have adopted state 

standards that meet or exceed the federal standards and can enforce 

these standards.14 Once a state certifies that it has met these conditions, 

the state is responsible for enforcing safety standards on state-regulated 

intrastate natural gas underground storage sites through inspections 

conducted by state employees, according to PHMSA officials. In addition, 

PHMSA officials told us that they would periodically assess whether 

states are meeting these conditions. PHMSA officials told us that PHMSA 

will have direct responsibility for inspecting federally-licensed interstate 

facilities for the next few years because federal safety standards are still 

being established, but officials noted that state inspectors could 

eventually seek permission from PHMSA to assume the role of inspecting 

interstate natural gas storage sites on behalf of PHMSA in the future. 

PHMSA officials also noted that PHMSA does not force states to 

participate in their pipeline safety program, and so in cases where a state 

chooses not to certify its safety enforcement program, PHMSA has stated 

 13American Petroleum Institute, API Recommended Practice 1170: Design and Operation 

of Solution-mined Salt Caverns Used for Natural Gas Storage, 1st ed. (Washington, D.C.: 

July 2015), and API Recommended Practice 1171: Functional Integrity of Natural Gas 

Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs, 1st ed. 

(Washington, D.C.: September 2015).

14Pub. L. No. 114-183, § 12(b) and 49 U.S.C. §§ 60105 and 60106.
Page 11 GAO-18-89 Natural Gas Storage Safety

that it will assign its own inspectors and staff to enforce federal natural 

gas storage safety standards in that state. The PIPES Act also requires 

PHMSA to set and charge user fees to operators that it can use for 

activities related to underground natural gas storage facility safety, 

subject to the expenditure of these fees being provided in advance in an 

appropriations act.15

Citing an urgent need to improve safety at natural gas storage sites, 

PHMSA issued an interim final rule that includes minimum safety 

standards based largely on API recommended practices in December 

2016. The rule took effect in January 2017 and provided that existing 

facilities (and those constructed by July 18, 2017) must meet the 

standards by January 18, 2018. PHMSA is now considering public 

comments on its interim standards, and it plans to finalize them by issuing 

a final rule by January 2018. PHMSA also has stated that it will delay 

enforcement of certain standards in the interim final rule until 1 year after 

issuance of the final rule.16

To meet the requirement under the PIPES Act, PHMSA issued minimum 

safety standards for natural gas storage through an interim final rule in 

December 2016,17 which took effect in January 2017.18 PHMSA issued 

the interim final rule—which allowed the safety standards to take effect 

more quickly than under the conventional regulatory process—and stated 

that any delay in adopting the standards would jeopardize the public 

 15Pub. L. No. 114-183, § 12(c).

16Department of Transportation Pipeline and Hazardous Materials Safety Administration, 

Notice: Pipeline Safety: Safety of Underground Natural Gas Storage Facilities; Petition for 

Reconsideration, 82 Fed. Reg. 28,224 (June 20, 2017).

17Department of Transportation Pipeline and Hazardous Materials Safety Administration, 

Interim Final Rule: Pipeline Safety: Safety of Underground Natural Gas Storage Facilities, 

81 Fed. Reg. 91,860 (Dec. 19, 2016)(codified at 49 C.F.R. parts 191 and 192).

18Typically, under the Administrative Procedure Act, federal agencies issue a final rule 

after publishing a proposed rule in the Federal Register and collecting and evaluating 

public comments on the proposed rule. However, interim final rules can be made effective 

immediately if the agency determines there is “good cause” to find that the notice and 

comment process would be impracticable, unnecessary, or contrary to the public interest. 

Under this good cause exception, the agency provides an opportunity for public comment 

after the interim final rule’s issuance. After an agency has collected and evaluated public 

comments, it can issue a final rule, which may be the same or similar to the interim final 

rule, or may be different. 

PHMSA Has Issued 

Interim Safety 

Standards and Plans 

to Finalize Them by 

January 2018

PHMSA Has Issued 

Minimum Standards in an 

Interim Final Rule
Page 12 GAO-18-89 Natural Gas Storage Safety

interest through risks to public safety and the environment. As a result, all 

415 natural gas storage sites are for the first time subject to federal 

regulation, including minimum safety standards as set forth in the interim 

final rule, and subject to revision in a final rule.

To develop the minimum safety standards, PHMSA considered industry 

consensus standards, as required by the PIPES Act. PHMSA had already 

advised operators to follow industry-recommended practices published by 

API, which develops consensus standards for the oil and gas industry. 

Specifically, in February 2016, before the passage of the PIPES Act, 

PHMSA issued a bulletin encouraging operators to follow the API 

recommended practices to update their safety programs.19 The API 

recommended practices contain many provisions that are mandatory, and 

other provisions that are nonmandatory. The interim final rule provides 

that the nonmandatory provisions of the recommended practices that are 

incorporated by reference in the rule are adopted as mandatory. 

PHMSA’s interim final rule requires operators of existing natural gas sites, 

and those constructed by July 18, 2017, to meet the requirements of 

certain sections of the API recommended practices identified in the rule 

by January 18, 2018. The API recommended practices address, among 

other things, general operations, monitoring the sites for potential leaks, 

and emergency response and preparedness. For new storage sites 

starting construction after July 18, 2017, the rule requires operators to 

meet all sections of the applicable API recommended practices.

According to PHMSA officials, PHMSA considered the recommendations 

of the task force in developing its minimum safety standards, as required 

by the PIPES Act, and continues to do so. PHMSA’s minimum safety 

standards addressed certain recommendations made by the task force, 

according to an analysis performed by PHMSA. However, PHMSA did not 

require operators to implement one key recommendation of the task force 

report with its minimum standards, according to PHMSA officials. In 

particular, the October 2016 task force report recommended that 

operators phase out most storage wells with single-point-of-failure 

designs—where the failure of a single component, such as a well casing, 

could lead to a large release of gas—by installing multiple points of 

control at each well. According to an API official, its recommended 

practices do not direct operators to phase out such wells because this 

 19Department Of Transportation Pipeline and Hazardous Materials Safety Administration, 

Advisory Bulletin ADB–2016–02: Pipeline Safety: Safe Operations of Underground 

Storage Facilities for Natural Gas, 81 Fed. Reg. 6,334 (Feb. 5, 2016).
Page 13 GAO-18-89 Natural Gas Storage Safety

practice may not significantly improve safety in all cases; for example, this 

practice may not have prevented the leak at Aliso Canyon. The API 

official and PHMSA officials noted that API recommended practices direct 

operators to assess the risks at their sites and to take steps to address 

these risks. According to PHMSA officials, assessing the risks of a site 

could include identifying wells with a single point of failure and developing 

steps to mitigate this risk. Mitigating the risk could include installing 

multiple points of control for certain wells, among other possible mitigation 

steps.20 Neither PHMSA nor API officials could tell us how many of the 

approximately 17,000 wells at the nation’s 415 natural gas storage sites 

have single-point-of-failure designs, because this information has not 

been centrally gathered to date. However, PHMSA plans to gather 

information about how many storage wells have single-point-of-failure 

designs by asking operators to provide this information as part of a 

required annual report.21

To fund its enforcement of its minimum safety standards, PHMSA also 

issued a notice to set the user fees that PHMSA charges operators, as 

required by the PIPES Act. In November 2016, PHMSA published a 

notice of agency action and request for comment, describing its user fee 

structure.22 PHMSA collected public comments, evaluated them, and 

finalized its user fee structure in April 2017.23 As set forth in this notice, 

PHMSA will charge each operator based on the size of the operator’s 

storage sites as measured by working gas capacity range. The notice 

 20According to the API official, this practice is an example of “performance-based 

language,” which allows companies and sites to select the most appropriate manner to 

achieve compliance, based on their circumstances. API has noted that this practice has 

been shown to improve pipeline safety. 

21PHMSA plans to require operators to annually report this information using PHMSA 

Form 7100.4-1. In its interim final rule, PHMSA required natural gas storage site operators 

to begin submitting these data using this form on or before July 18, 2017 (see 49 C.F.R. § 

191.17). According to PHMSA officials, the Office of Management and Budget (OMB) has 

recently approved this form. As a result, PHMSA will begin collecting data that reflect 

calendar year 2017 by its due date of March 15, 2018.

22Department of Transportation Pipeline and Hazardous Materials Safety Administration, 

Pipeline Safety: Underground Natural Gas Storage Facility User Fee, Notice of agency 

action and request for comment, 81 Fed. Reg. 78,261 (Nov. 7, 2016). The notice states 

that it advises natural gas storage facility operators about its proposed PHMSA pipeline 

user fee assessment and rate structure.

23Department of Transportation Pipeline and Hazardous Materials Safety Administration, 

Pipeline Safety: Underground Natural Gas Storage Facility User Fee, Notice of agency 

action, 82 Fed. Reg. 16,874 (Apr. 6, 2017). 
Page 14 GAO-18-89 Natural Gas Storage Safety

stated that PHMSA plans to collect a total of up to $8 million annually in 

fees from all operators combined; however, PHMSA may seek authority 

to increase or decrease the amount it charges operators if it finds that the 

cost of inspection and enforcement is more or less than it initially 

estimated, according to PHMSA officials. Following enactment of an 

appropriations act provision, PHMSA is authorized to use the fees it 

collects to fund its enforcement activities and plans to use a portion of the 

fees to reimburse states for enforcing its minimum safety standards, 

according to PHMSA officials.

Table 1 provides a timeline of key events in the development of PHMSA’s 

minimum safety standards.
Page 15 GAO-18-89 Natural Gas Storage Safety

Table 1: Timeline of Key Events in the Development of the Pipeline and Hazardous Materials Safety Administration’s (PHMSA) 

Minimum Standards for Natural Gas Storage Safety

Date Event

July 2015 to

September 2015

• The American Petroleum Institute (API) releases industry-recommended practices for natural 

gas storage 

October 2015 to

February 2016

• October 2015: A natural gas leak is detected at the Aliso Canyon Underground Storage Facility 

outside Los Angeles, California

• November 2015: After several unsuccessful attempts to stop the leak at Aliso Canyon, the site 

operator begins drilling a second well to intercept and stop the leak underground

• February 2016: The Aliso Canyon site operator completes the relief well and stops the leak

February 2016 • The Department of Transportation’s (DOT) PHMSA advises operators to voluntarily follow API 

recommended practices 

April 2016 • The Department of Energy (DOE) and PHMSA form a task force to examine the Aliso Canyon 

incident and to develop recommendations on how similar incidents could be prevented in the 

future 

June 2016 • Congress passes and the President signs the Protecting Our Infrastructure of Pipelines and 

Enhancing Safety (PIPES) Act of 2016, which formalized by statute the task force formed by 

DOE and PHMSA to study natural gas storage safety, and directs DOT to issue minimum 

standards for natural gas storage safety

November 2016 • PHMSA publishes a notice of its proposed fee structure, stating that it plans to annually charge 

operators up to $8 million in fees to fund its enforcement work, and requests public comments

December 2016 • PHMSA issues an interim final rule containing minimum safety standards based on API 

recommended practices, and requests public comments on the standards

January 2017 • Interim final rule containing minimum safety standards goes into effect

April 2017 • PHMSA finalizes its fee structure for operators 

June 2017 • In response to a petition for reconsideration, PHMSA publishes a notice stating that it intends 

to address the issues raised by comments it collected from industry and the public, and that it 

will not issue certain enforcement citations to operators until January 2019

• Following an appropriation provision allowing PHMSA to obligate up to $8 million from fees for 

its natural gas safety enforcement program, PHMSA collects about $2 million and plans to 

collect the remaining $6 million in the coming months

Source: GAO analysis of PHMSA publications and documents. | GAO-18-89

Since issuing its interim final rule, PHMSA has been collecting public 

comments and plans to adjust some aspects of the rule in response to 

comments from the public, industry representatives, and others. PHMSA 

plans to finalize its minimum safety standards by replacing its interim final 

rule with a final rule in January 2018, and has delayed some dates for 

when it expects operators to comply with some aspects of its standards. 

PHMSA’s interim final rule states that, with respect to incorporation by 

reference of the standards, the nonmandatory provisions it adopted are 

adopted as mandatory provisions. API and two other organizations 

representing natural gas utilities and transmission companies submitted 

comments asking PHMSA to reconsider how it used the API 

PHMSA Is Considering 

Comments on Its Interim 

Final Rule and Plans to 

Issue Final Safety 

Standards in January 

2018
Page 16 GAO-18-89 Natural Gas Storage Safety

recommended practices in its minimum safety standards.24 While API and 

the other industry representatives agreed that it was appropriate for 

PHMSA to use API recommended practices for its minimum safety 

standards, they stated that making all portions mandatory would make the 

standards burdensome. In June 2017, PHMSA published a notice in the 

Federal Register stating that it would consider these comments as it 

finalized its minimum safety standards, which it stated it expects to issue 

by January 2018. The notice stated further that PHMSA will not issue any 

enforcement citations to operators for failure to meet any standards that 

were nonmandatory but that were converted to mandatory by provisions 

of the interim final rule until 1 year after it issues the final rule.25

PHMSA also provided additional guidance and clarifications to operators 

about scheduling and its plans for enforcement. During the development 

of its interim final rule, PHMSA noted that some of the provisions in the 

minimum safety standards may take operators several years to fully 

implement. According to PHMSA officials, these provisions recommend

that operators carefully inspect their natural gas storage sites, identify any 

conditions that do not meet industry-recommended practices, and then 

improve conditions at the sites by prioritizing the greatest risks and 

implementing preventative measures to mitigate and remediate these 

risks over a number of years. As a result, PHMSA published guidance on 

its website stating that it expects operators to make and implement plans 

to inspect and remediate risks found at their sites within 3 to 8 years 

following the effective date of the interim final rule.26

 24See American Gas Association, American Petroleum Institute, American Public Gas 

Association, and Interstate Natural Gas Association of America, “Petition for 

Reconsideration of ‘Safety of Underground Natural Gas Storage Facilities Interim Final 

Rule,’ 81 Fed. Reg. 91,860 (Dec. 19, 2016), Docket No. PHMSA-2016-0016,” Letter to 

PHMSA, January 18, 2017. On April 17, 2017, the Interstate Natural Gas Association of 

America withdrew from the petition for reconsideration. 

25U.S. Department of Transportation Pipeline and Hazardous Materials Safety 

Administration, Notice: Pipeline Safety: Safety of Underground Natural Gas Storage 

Facilities; Petition for Reconsideration, 82 Fed. Reg. 28,224 (June 20, 2017). 

26U.S. Department of Transportation Pipeline and Hazardous Materials Safety 

Administration, Pipeline Technical Resources: Underground Natural Gas Storage: FAQs, 

accessed August 1, 2017, https://primis.phmsa.dot.gov/ung/faqs.htm.
Page 17 GAO-18-89 Natural Gas Storage Safety

To enforce PHMSA’s safety standards, the agency’s officials have taken 

a variety of steps to establish a safety enforcement program for natural 

gas storage sites, but they have not yet followed certain leading practices 

of strategic planning in starting PHMSA’s natural gas storage program.27

Specifically, PHMSA officials have started developing a training program 

for natural gas storage inspectors. They also have established a strategic 

goal and begun developing a training performance goal for their natural 

gas safety enforcement program. However, they have not yet followed 

certain leading practices for strategic planning—the systematic process 

for defining desired outcomes and translating this vision into goals and 

steps to achieve them. For example, PHMSA’s training performance goal 

does not define the level of performance officials hope to achieve or 

address all core program activities, such as conducting effective 

inspections. In addition, PHMSA has not used baseline data or budgetary 

information to inform the development of performance goals. PHMSA 

officials explained that they are still developing performance goals for 

their new program and collecting relevant data.

To enforce the agency’s safety standards, PHMSA officials have taken a 

variety of steps to establish a safety enforcement program for natural gas 

storage sites by January of 2018. For example, PHMSA officials have 

started developing a training program for natural gas storage inspectors. 

They have identified learning objectives for the program and have begun 

developing learning materials. According to PHMSA officials, developing 

a training program for inspectors is central to safety enforcement efforts, 

in part because PHMSA has a limited number of staff members with 

expertise in natural gas storage. For example, PHMSA had 10 employees 

with natural gas storage experience as of August 2017, according to 

PHMSA officials. In addition, PHMSA officials have completed eight

safety assessments of selected natural gas storage operators to 

document the initial condition of gas storage sites and safety practices. 

According to PHMSA officials, their methodology for conducting these 

 

27PHMSA’s oversight activities do not have a unique program activity code in the agency’s 

budget, according to PHMSA officials. Fees collected from natural gas storage operators 

to fund natural gas storage oversight will be deposited in PHMSA’s Underground Natural 

Gas Storage Facility Safety account. Subsequently, obligations made for natural gas 

storage oversight activities will be tracked as separate subareas within the Pipeline Safety 

Program’s program activity codes for operations and grants. However, in consultation with 

PHMSA, for the purposes of this report we have referred to PHMSA’s oversight activities 

as a program. 

PHMSA Has Taken 

Steps to Establish an 

Enforcement Program 

but Has Not Yet 

Followed Certain 

Leading Practices of 

Strategic Planning

PHMSA Has Taken Steps 

to Establish a Natural Gas 

Storage Safety 

Enforcement Program
Page 18 GAO-18-89 Natural Gas Storage Safety

assessments involved visiting a cross section of operators, including 

operators of interstate and intrastate sites and multiple types of facilities.

PHMSA officials also have developed workload and budget estimates for 

their new program, according to PHMSA documentation. In recent years, 

the Office of Pipeline Safety, which will be responsible for natural gas 

storage inspections in addition to pipeline inspections and other activities, 

has initiated about 1,100 inspections annually, according to PHMSA data. 

When natural gas storage site inspections begin, PHMSA officials 

estimate that the Office of Pipeline Safety’s inspection workload could 

increase 14 percent due to their new responsibilities. They reached this 

estimate by dividing the 203 new natural gas storage units they anticipate 

needing to inspect by the total number of inspection units they currently 

inspect.28 To meet the demands of this increased workload, officials 

estimate that PHMSA will need $2 million annually to fund 6 new 

inspector positions, training, travel, and other expenses associated with 

managing the natural gas storage safety enforcement program. With this 

number of inspectors, PHMSA officials believe that they can inspect all 

203 natural gas storage units within about 4 years. Because PHMSA 

officials expect that many states that have previously conducted similar 

inspections will help PHMSA conduct inspections, officials also estimate 

that PHMSA will need to provide $6 million annually to states. However, 

PHMSA officials noted that their estimates may change as they gain 

additional information about the program. Specifically, after PHMSA 

begins initial inspections in early 2018, officials will have more information 

about the time it takes to inspect natural gas storage sites. By the end of 

fiscal year 2018, they will have even more information with which to 

develop more precise workload and budget estimates for the program, 

according to these officials.

To ensure that the states assisting PHMSA are fully qualified to enforce 

the federal government’s minimum safety standards, PHMSA officials 

have begun developing a state certification program. This has involved 

drafting certification documents and contacting potential state partners. 

As of June 2017, PHMSA officials expected all states with intrastate 

natural gas storage sites to pursue certification. However, officials 

 28According to a workload estimate document prepared by PHMSA officials, PHMSA 

officials currently inspect 1,439 “inspection units”—collections of assets that an inspector 

could inspect in 1 week—and PHMSA’s new natural gas storage inspections will likely 

increase its workload by an additional 203 inspection units, bringing the total number of 

inspection units up to 1,642. 
Page 19 GAO-18-89 Natural Gas Storage Safety

explained that they may not know until the end of fiscal year 2017 exactly 

how many states will pursue certification. If some states choose not to 

pursue certification or are not approved by PHMSA, PHMSA will be 

responsible for inspecting natural gas storage sites in those states, which 

could increase its inspection workload beyond the level it has estimated. 

For states that choose certification and are approved, PHMSA plans to 

use grants to fund up to 80 percent of state inspection costs. However, 

PHMSA officials told us that PHMSA may not be able to fund states to 

this level, depending on the approved costs requested by all states and 

levels of funding PHMSA receives through the appropriations process. In 

either circumstance, PHMSA’s grant program for certified state partners 

leverages state dollars, since it requires states to fund the portions of their 

programs not covered by grant funding.

PHMSA also has established a strategic goal for its natural gas safety 

enforcement program, but it has not yet followed other leading practices 

for strategic planning.29 Specifically, PHMSA officials told us that their 

new enforcement program will be guided by one of PHMSA’s existing 

strategic goals—to promote continuous improvement in safety 

performance.30 PHMSA officials also told us that they are developing a 

performance goal for their training program and that other performance 

goals are still being identified and developed. The Government 

Performance and Results Act of 1993 (GPRA), as amended—which 

seeks to improve the effectiveness of federal programs by establishing a 

system for agencies to set goals for program performance and measure 

results—defines a performance goal as the target level of performance 

expressed as a tangible, measurable objective against which actual 

achievement is to be compared.31 For example, in the area of weather 

forecasting, we have previously reported that such a goal could be to 

increase the lead time for predicting tornadoes from 7 to 9 minutes.32

 29Strategic goals constitute a set of policy, programmatic, and management objectives for 

the programs and operations covered in an agency’s strategic plan, and they serve as a 

framework from which performance goals are derived. 

30PHMSA’s goal to promote continuous improvement in safety performance is one of five 

strategic goals identified in PHMSA 2021: Safety – Innovation – Trust, the agency’s 

strategic framework through 2021. Implementation strategies for meeting these strategic 

goals can be found in PHMSA 2021 Business Plan - 2017. 

31Pub. L. No. 103-62 (1993).

32GAO, Agencies’ Strategic Plans Under GPRA: Key Questions to Facilitate 

Congressional Review, GAO/GGD-10.1.16 (Washington, D.C.: May 1997). 

PHMSA Has Established a 

Strategic Goal but Has Not 

Yet Followed Certain 

Leading Practices of 

Strategic Planning
Page 20 GAO-18-89 Natural Gas Storage Safety

PHMSA has not yet followed certain leading practices for strategic 

planning, as it has not: (1) defined the level of performance or fully 

addressed core program activities with its existing performance goal; or 

(2) used baseline data and other data or budget information to inform and 

refine performance goals.

Our prior work has identified several leading practices for strategic 

planning that PHMSA has not yet followed, such as setting goals that 

define a certain level of performance and address all core program 

activities. Some of this prior work has examined requirements under 

GPRA and the GPRA Modernization Act of 2010.33 GPRA, which was 

significantly enhanced by the GPRA Modernization Act of 2010, requires 

agencies to develop annual performance plans that, among other things, 

establish performance goals to define the level of performance to be 

achieved.34 We have previously reported that requirements under these 

acts can serve as leading practices for planning at lower levels of the 

agency.35 As one of several operating administrations within DOT, 

PHMSA would be considered a lower level of the agency. In addition, we 

have found that a key attribute of successful performance measures is 

that they reflect the full range of core program activities.36 Moreover, we 

have found that a key practice for helping federal agencies enhance and 

sustain collaborative efforts with other agencies is to define and articulate 

a common outcome or purpose they are seeking to achieve.37

While PHMSA has taken some steps to plan strategically for its new 

program, it has not followed certain leading practices of strategic 

planning. For example, PHMSA has developed a performance goal for its 

 33Pub. L. No. 103-62 (1993) and Pub. L. No. 111-352 (2011). 

34Under GPRA, agencies are to prepare performance plans to systematically provide 

decisionmakers with information on the results to be achieved for a proposed level of 

resources. These plans are to reinforce the connection between the long-term strategic 

goals outlined in agencies’ strategic plans and the day-to-day activities of their program 

managers and staff. In so doing, annual performance plans provide a basis for 

establishing accountability for results. 

35GAO, Grants Management: EPA Partially Follows Leading Practices of Strategic 

Workforce Planning and Could Take Additional Steps, GAO-17-144 (Washington, D.C.: 

Jan. 9, 2017). 

36GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season 

Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002). 

37GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain 

Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).

Defining Level of Performance 

and Addressing All Core 

Program Activities
Page 21 GAO-18-89 Natural Gas Storage Safety

training program, and agency officials told us that they plan to review the 

number of students who pass their gas storage training course as a 

measure of the agency’s training performance goal. However, with this 

measure PHMSA has not defined the level of performance to be 

achieved. An example of a measure of the agency’s training performance 

goal that defines the level of performance could be one that specifies that 

a certain percentage of students will pass the course on their first attempt. 

In addition, PHMSA has not yet developed performance goals for other 

core program activities, such as conducting effective inspections. 

According to PHMSA subject-matter experts, one of the critical tasks 

associated with inspecting a gas storage site will be determining whether 

the operator has met all well monitoring requirements specified in API’s

Recommended Practice 1171, which addresses the functional integrity of 

gas storage in depleted hydrocarbon reservoirs and aquifers.38 An 

example of a performance goal that could indicate whether PHMSA’s 

inspections are effective could be to annually reduce, by a certain 

percentage, the number of operators that do not meet the well monitoring 

requirements of Recommended Practice 1171. Another critical task 

identified by PHMSA’s subject-matter experts will be to determine 

whether the operator has followed its own risk management plan for gas 

storage sites—another area where PHMSA has not developed a 

performance goal. An example of a performance goal in this area could 

be to annually reduce, by a certain percentage, the number of gas 

storage operators that have not followed their own risk management 

plans.

PHMSA officials acknowledged that their performance goals are not yet 

complete and said that they would strive to refine performance goals as 

they continue developing the program; however, PHMSA has not yet 

done so. As they do so, ensuring that their performance goals define the 

level of performance to be achieved and address core program activities 

could help them ensure that they effectively track progress toward their 

strategic goal and make adjustments to activities and resources, if 

needed, to better meet the goal. In addition, because PHMSA plans to 

leverage state resources to oversee gas storage sites, the success of its 

gas storage program will depend, in part, on collaboration with state 

 38The term “functional integrity” refers to the total reliability of the storage system, 

including the physical integrity of the reservoir and well components as well as the 

performance reliability assurance established by management systems employed by the 

storage operator. American Petroleum Institute, API Recommended Practice 1171, 

Chapter 9.
Page 22 GAO-18-89 Natural Gas Storage Safety

partners. Establishing performance goals for the program could help 

PHMSA coordinate efforts and resources with the states that are 

expected to assist PHMSA with inspections.

Another leading practice of strategic planning involves using baseline and 

trend data to inform performance goals, according to our prior work.39

Baseline data—data collected about operations before oversight begins—

can serve as a basis for comparison with subsequently collected trend 

data. We have previously reported that baseline and trend data can 

provide a context for drawing conclusions about whether performance 

goals are reasonable and appropriate.40 For example, we found in 1999 

that the Department of Education was able to use such information to 

gauge the appropriateness of its goals for reducing the default rate on 

student loans provided through the Federal Family Education Loan 

program.41 The program’s annual plan provided baseline and trend data 

for the default rate, which indicated that the rate declined from 22.4 

percent to 10.4 percent from fiscal years 1990 to 1995. According to 

Education’s analysis of the data, future declines were likely to be steady 

but smaller because of the large number of high-default schools that had 

already been eliminated from the program. For fiscal year 1999, 

Education set a goal of reducing the default rate to 10.1 percent of 

borrowers.

For PHMSA’s natural gas storage program, PHMSA will have access to 

baseline data—and eventually trend data—over time that could inform the 

development of performance goals and subsequent refinement of them. 

PHMSA officials told us that they have not yet used such data to inform 

the development of their performance goal because they are still in the 

process of collecting relevant data. For example, officials told us that, 

over time, they will have access to data about operators’ facilities, 

functional integrity work, and operations and maintenance procedures 

 39GAO, Agency Performance Plans: Examples of Practices That Can Improve Usefulness 

to Decisionmakers, GAO/GGD/AIMD-99-69 (Washington, D.C.: Feb. 26, 1999).

40GAO/GGD/AIMD-99-69.

41GAO/GGD/AIMD-99-69.

Using Baseline Data to Inform 

Performance Goals
Page 23 GAO-18-89 Natural Gas Storage Safety

starting in early 2018.42 These data will likely include the number of wells 

that have leaked and been repaired during the last calendar year. As 

specified in PHMSA’s minimum safety standards, PHMSA also plans to 

collect safety and incident reports to track gas releases, deaths, and 

injuries resulting in hospitalizations. In addition, in August of 2017, 

PHMSA officials completed eight industry safety assessments, which 

involved visiting natural gas storage sites and studying sites’ safety 

procedures. As previously mentioned, these assessments aimed, in part, 

to document the initial condition of gas storage sites and safety practices. 

Agency officials told us that they had planned to use the data they collect 

from these assessments to inform the agency’s state certification and 

inspection programs. They did not specify whether or how they intend to 

use these data to inform their performance goals. As PHMSA continues 

developing performance goals for its natural gas storage program, using 

available data to inform and refine these goals could help the agency 

ensure that its goals are reasonable and appropriate.

We also have reported that comparing information about budgetary 

resources with information about performance goals can help 

decisionmakers determine whether their performance goals are 

achievable. Specifically, we have reported that decisionmakers can better 

compare planned levels of accomplishment with the resources requested 

if they have information about how funding levels are expected to achieve 

a discrete set of performance goals.43 For example, we reported in a best

practices report about strategic planning that the Internal Revenue 

Service (IRS) included in its performance plan for 1999 the budget 

amounts that corresponded with past performance levels. Table 2 

illustrates how IRS used this information to inform proposed performance 

levels for the upcoming year. Moreover, GPRA requires agencies to 

prepare an annual performance plan covering each program activity set 

forth in the budget and, among other things, describe the resources 

required to meet performance goals. As previously mentioned, we have 

found that GPRA requirements can serve as leading practices for 

planning at lower levels of the agency.

 42PHMSA officials noted that they do not expect operators to produce comprehensive 

integrity assessments or fully estimate safety risks at their natural gas storage sites in 

2018. Instead, PHMSA officials stated that they expect operators will complete these 

integrity assessments and take preventative and mitigative measures in 3 to 8 years. 

PHMSA will require operators to submit these data annually through PHMSA Form 

7100.4-1. 

43GAO/GGD/AIMD-99-69.

Using Budgetary Information to 

Inform Performance Goals
Page 24 GAO-18-89 Natural Gas Storage Safety

Table 2: Excerpt From the Department of the Treasury’s Fiscal Year 1999 Annual Performance Plan Featuring the Internal 

Revenue Service 

Performance Plans for FY 1999 and FY 1998, and Performance Report for FY 1997 Data

FY 1995a FY 1996a FY 1997a FY 1998 FY 1999

Actual Actual Plan Actual Final Plan Proposal

Budget Authority ($000s) $814, 128 $780,512 $788, 138 $794,950 $850,787 $888,408 

Direct FTE 21,307 20,460 15,481 13,396 15,105 15,113

Performance Plan

A. Performance Goal: Improve Customer Service

Performance Measure(s):

1. Total Number of Individual Refunds Issued

(millions)b 88.7 85.5 84.6 87.9 89.6 93.3

2. Refund Timeliness—Paper (days) 36 38 40 38 40 40

3. Refund Timeliness—Electronic Filing (days) 21 15.5 21 14.5 21 21

4. Processing Accuracy Rate—Paper Filing 95% 95% 95% 95.2% 95% 95%

5. Processing Accuracy Rate—Electronic Filing 99% 99% 99% 99.3% 99% 99%

6. Notice Accuracy 98.2% 98.1% N/A 98.6% 98.5% 98.5%

7. Number of Telefile Returns (millions) 0.7 2.8 N/A 4.7 5.5 5.9

B. Performance Goal: Increase Compliance

Performance Measure(s):

8. Number of Primary Returns Processed 

(millions)b 193.15 196.2 197.9 202.6 208.4 211.8

C. Performance Goal: Increased Productivity

Performance Measure(s):

9. Percent of Individual Returns Filed 

Electronically 8.0% 10.2% 13.0% 15.9% 17.0% 19.5%

10. Percent of Dollars Received Electronically 24.7% 40.6% 48.4% 78.2%

11. Percent of Dollars Received via Third Party 

Processors (Lockbox)c 65.3% 70.9% 70.9% 70.9%

Source: Department of the Treasury Fiscal Year 1999 Performance Plan. | GAO-18-89

a

IRS originally reported that Service Center Adjustments moved to the Customer Service activity as 

part of a restructure in fiscal year 1998. As a result, fiscal year 1997 has been restructured to mirror 

the fiscal year 1998 structure; fiscal years 1995 and 1996 are in the old budget structure.

b

IRS originally reported that this is not a measure, but a projection for budget purposes, and was not 

used in the business review.

c

IRS originally reported that no additional payments were planned to migrate to Lockbox.

Assessing whether the new program’s performance goals are achievable 

given budgetary resources is important at a time when PHMSA officials 

are managing other new resources and responsibilities. For example, in 

addition to requiring DOT to establish minimum safety standards for 
Page 25 GAO-18-89 Natural Gas Storage Safety

natural gas storage sites, the PIPES Act of 2016 also requires DOT to 

update minimum safety standards for small-scale liquefied natural gas 

pipeline facilities. To carry out its responsibilities, PHMSA has received 

additional resources in recent years. As shown in figure 3, PHMSA’s 

Pipeline Safety Program has seen its total budgetary resources available 

increase from about $95 million in fiscal year 2007 to about $175 million 

in fiscal year 2016.44 In addition, the Consolidated Appropriations Act for 

fiscal year 2017 included a provision allowing for the obligation of up to 

$8 million from fees collected in fiscal year 2017 from operators for 

PHMSA’s natural gas storage program.45 These fees will be deposited in 

an Underground Natural Gas Storage Facility Safety account within 

PHMSA’s Pipeline Safety Fund and will be added to the Pipeline Safety 

Program’s total budgetary resources available for fiscal year 2017.

 44Budgetary resources available for obligation may include an agency’s new budget 

authority and unobligated balances brought forward from the prior year. Budgetary 

resources available for obligation may also include fees collected to offset expenses. 

Budget authority is the authority provided by federal law to enter into financial obligations 

that will result in immediate or future outlays involving federal government funds. 

45Pub. L. No. 115-31 (2017). 
Page 26 GAO-18-89 Natural Gas Storage Safety

Figure 3: Total Budgetary Resources Available for the Pipeline and Hazardous

Materials Safety Administration’s (PHMSA) Pipeline Safety Program, Fiscal Years 

2007–2016

Note: Budgetary resources available for obligation may include an agency’s new budget authority and 

unobligated balances brought forward from the prior year. Budgetary resources available for 

obligation may also include fees collected to offset expenses. Budget authority is the authority 

provided by federal law to enter into financial obligations that will result in immediate or future outlays 

involving federal government funds. PHMSA’s Office of Pipeline Safety is responsible for the 

agency’s natural gas storage safety program and other activities. This figure does not reflect funding 

for natural gas storage inspections, as these activities were not funded until fiscal year 2017.

PHMSA is not yet in a position to use budget information to inform or 

refine performance goals for its natural gas storage program because 

PHMSA officials are still developing these goals and PHMSA lacks key 

data, such as data on the time it takes—and therefore the budgetary 

resources required—to inspect natural gas storage sites. As previously 

mentioned, PHMSA will begin inspections in early 2018, and officials will 

have a better understanding of how long it takes to inspect natural gas 

storage sites by the end of fiscal year 2018. As PHMSA officials continue 

developing performance goals and finish collecting relevant data, using 

information about budgetary resources to inform and refine these goals 

may help PHMSA ensure that its goals are achievable.
Page 27 GAO-18-89 Natural Gas Storage Safety

Natural gas storage sites are key elements of our nation’s energy system, 

helping ensure that natural gas is available when demand peaks. As 

evidenced by the large-scale leak of natural gas outside Los Angeles that 

started in 2015 and extended into 2016, leaks from these sites can cause 

economic disruptions and environmental damage. These sites recently 

became subject to national safety standards, which are subject to further 

revision.

PHMSA has taken a variety of steps to meet its new responsibilities for 

overseeing natural gas storage sites, such as developing a training 

program for inspectors and a performance goal for training. However, 

PHMSA has not yet followed certain leading practices of strategic 

planning in starting PHMSA’s new safety enforcement program. For 

example, PHMSA’s only current performance goal does not define the 

level of performance officials are working to achieve, and PHMSA does 

not currently have goals that address other core program activities, such 

as conducting effective inspections. PHMSA also has not yet used the 

baseline data it is collecting to develop its performance goals. PHMSA 

officials explained that they are still developing performance goals for 

their new program and collecting data. As the agency continues to 

develop these goals, ensuring that performance goals define the level of 

performance and address all core program activities could help the 

agency better track progress toward its strategic goal and adjust activities 

and resources, if needed, to better meet the goal. Using baseline data to 

develop these goals could help PHMSA ensure that its goals are 

reasonable and appropriate. Finally, once PHMSA finalizes performance 

goals for the program and collects relevant data over time as well as 

budgetary information, using these data and information when available 

to inform and refine performance goals may help PHMSA ensure that its 

goals are achievable.

We are making the following two recommendations to PHMSA. 

The Administrator of PHMSA should ensure that PHMSA defines levels of 

performance, addresses core program activities, and uses baseline data 

as it continues developing performance goals for its natural gas storage 

program. (Recommendation 1)

The Administrator of PHMSA should ensure that PHMSA uses other data 

and information about budgetary resources as they become available to 

inform and refine its performance goals. (Recommendation 2)

Conclusions

Recommendations for 

Executive Action
Page 28 GAO-18-89 Natural Gas Storage Safety

We provided a draft of this report to DOT for review and comment. In 

written comments, DOT concurred with the report’s recommendations 

and provided additional information on steps they are taking or plan to 

take as part of their oversight of natural gas storage sites. In addition, 

DOT stated that it would provide a detailed response to each 

recommendation within 60 days of our final report’s issuance. The 

complete comment letter is reproduced in appendix III.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to the 

appropriate congressional committees, the Secretary of Transportation, 

and other interested parties. In addition, the report will be available at no 

charge on the GAO website at http://www.gao.gov.

If you or members of your staff have any questions about this report, 

please contact us at (202) 512-3841, gomezj@gao.gov, or 

ruscof@gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

GAO staff who made key contributions to this report are listed in 

appendix IV.

J. Alfredo Gómez 

Director, Natural Resources and Environment

Frank Rusco

Director, Natural Resources and Environment

Agency Comments
Page 29 GAO-18-89 Natural Gas Storage Safety

List of Requesters

The Honorable Eddie Bernice Johnson

Ranking Member

Committee on Science, Space, and Technology

House of Representatives

The Honorable Suzanne Bonamici

Ranking Member

Subcommittee on Environment

Committee on Science, Space, and Technology

House of Representatives

The Honorable Don Beyer

Ranking Member

Subcommittee on Oversight

Committee on Science, Space, and Technology

House of Representatives

The Honorable Marc Veasey

Ranking Member

Subcommittee on Energy

Committee on Science, Space, and Technology

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 30 GAO-18-89 Natural Gas Storage Safety

In this report, we examine (1) the status of the Pipeline and Hazardous 

Materials Administration’s (PHMSA) efforts to implement the requirement 

under the Protecting Our Infrastructure of Pipelines and Enhancing Safety 

(PIPES) Act of 2016 to issue minimum safety standards for natural gas 

storage sites, 1 and (2) the extent to which PHMSA has planned 

strategically to enforce its safety standards for natural gas storage sites.

To examine the status of PHMSA’s efforts to implement the requirement 

to issue minimum safety standards for natural gas storage sites, we 

examined laws, regulations, and agency documents that describe the 

authority, time frames, and enforcement goals for implementing new 

federal rules under the PIPES Act. Specifically, we reviewed the PIPES 

Act to identify requirements that the act directed to the Department of 

Transportation (DOT), or PHMSA. To understand PHMSA’s 

implementation of DOT’s requirements under the act, we reviewed 

PHMSA notices and regulations as presented in the Federal Register and 

discussed the information in these documents with agency officials. We 

also reviewed guidance documents on the PHMSA website intended to

provide natural gas storage operators with more detailed guidance and 

discussed the documents with agency officials. We reviewed an October 

2016 report, mandated by the act, which was issued by a task force led 

by the Department of Energy (DOE). We also obtained and reviewed 

copies of recommended practices issued by the American Petroleum 

Institute (API), which issues industry consensus standards for the oil and 

gas industry, and interviewed API officials to better understand these 

recommended practices.

We also interviewed agency officials. Specifically, we interviewed officials 

with PHMSA, the Federal Energy Regulatory Commission, the Bureau of 

Land Management within the Department of the Interior, and the 

Environmental Protection Agency, to understand how they participated in 

the task force and to what degree they have responsibilities related to 

natural gas storage safety enforcement.

In addition, we obtained data from PHMSA and DOE’s Energy 

Information Administration about natural gas storage sites to gain an 

estimate of the number and regulatory status of various natural gas 

storage sites, their locations, and other details. We assessed the 

reliability of these data by (1) corroborating these data with other sources, 

 1

Pub. L. No. 114-183 (2016). 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 31 GAO-18-89 Natural Gas Storage Safety

(2) reviewing existing information about the data and the system that 

produced them, and (3) interviewing agency officials knowledgeable 

about the data. We determined that these data were sufficiently reliable 

for the purposes of this report. We also interviewed agency officials at 

DOT and PHMSA, including discussing agency requirements under the 

PIPES Act and how PHMSA planned to implement its responsibilities. To 

better understand the operation and control of natural gas storage sites, 

we conducted a site visit to the Aliso Canyon Gas Storage Facility in 

California and spoke to officials representing the operator of the site, and 

state government officials responsible for safety enforcement at the site.

To examine the extent to which PHMSA has planned strategically to 

enforce safety standards for natural gas storage sites, we compared 

information we gathered from PHMSA officials and documents with 

leading practices for strategic planning identified by our prior work, which 

were identified by examining requirements under the Government 

Performance and Results Act (GPRA) of 1993.2 We have previously 

reported that requirements under GPRA and the GPRA Modernization 

Act of 2010 can serve as leading practices for planning at lower levels of 

the agency.3 We also interviewed PHMSA officials—including budgetary, 

policy, and programmatic officials—about their planning efforts for the 

natural gas storage program. In addition, we reviewed regulations and 

documents that reflect agency planning efforts, including: PHMSA’s 

interim final rule on the safety of underground natural gas storage 

facilities; agency guidance, such as frequently asked questions for 

operators of natural gas storage sites;4 and agency planning documents, 

such as the Training Implementation Plan for Natural Gas Underground 

Storage Regulation Training,

5 PHMSA 2021 Business Plan - 2017,6 and 

 2

Pub. L. No. 103-62 (1993). 

3

GAO, Grants Management: EPA Partially Follows Leading Practices of Strategic 

Workforce Planning and Could Take Additional Steps, GAO-17-144 (Washington, D.C.: 

Jan. 9, 2017) and Pub. L. No. 111-352 (2011). 

4

Pipeline and Hazardous Materials Safety Administration, Pipeline Technical Resources: 

Underground Natural Gas Storage: FAQs, accessed August 1, 2017, 

https://primis.phmsa.dot.gov/ung/faqs.htm. 

5

Pipeline and Hazardous Materials Administration, Training Implementation Plan for 

Natural Gas Underground Storage Regulation Training (Mar. 31, 2017). 

6

Pipeline and Hazardous Materials Administration, PHMSA 2021 Business Plan - 2017. 
Appendix I: Objectives, Scope, and 

Methodology

Page 32 GAO-18-89 Natural Gas Storage Safety

workload and budget estimates for the program.7 Using information 

obtained from these sources about PHMSA’s efforts to plan for its natural 

gas storage program, we compared PHMSA’s planning efforts with 

leading practices for strategic planning identified in our prior reports.8

We conducted this performance audit from November 2016 to November 

2017 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.

 7

Pipeline and Hazardous Materials Administration, Underground Natural Gas Storage 

Facilities Budget Estimates and untitled workload estimate document. 

8

GAO, Agency Performance Plans: Examples of Practices That Can Improve Usefulness 

to Decisionmakers, GGD/AIMD-99-69 (Washington, D.C.: Feb. 26, 1999). 
Appendix II: Number of Active Natural Gas 

Storage Sites as of January 2016 by State and 

Jurisdiction

Page 33 GAO-18-89 Natural Gas Storage Safety

Table 3 identifies the 415 natural gas storage sites active as of January 

2016, by state and jurisdiction. The number of natural gas storage sites 

that fall under federal or state jurisdiction in each state is presented, along 

with the total storage capacity of the sites. A natural gas storage site is 

considered to be under federal jurisdiction—also known as “interstate”—if 

the site is linked to a federally-regulated interstate pipeline permitted by 

the Federal Energy Regulatory Commission. Otherwise, sites are under 

state jurisdiction.

The sites represented in this table were compiled by the Department of 

Energy’s Energy Information Administration in 2016, and provided by the 

Department of Transportation’s Pipeline and Hazardous Materials Safety 

Administration (PHMSA). EIA collects these data using a survey of 

natural gas storage site operators. According to a PHMSA document, 

PHMSA used these data to, among other things, identify natural gas 

storage sites and calculate the amount of user fees that it charged 

operators in 2017 (the first year PHMSA collected these user fees) to 

fund its inspection and enforcement programs. PHMSA plans to update 

its information about natural gas storage sites using data submitted by 

operators, as required by its interim final rule.1 This rule requires natural 

gas storage site operators to submit these data on or before July 18, 

2017. PHMSA plans to require operators to annually submit this 

information using a form. According to PHMSA officials, the Office of 

Management and Budget recently approved this form. As a result, 

PHMSA will begin collecting data that reflect calendar year 2017 by its 

due date of March 15, 2018. PHMSA officials told us that it will take about 

5 to 6 months to develop a website that will allow PHMSA to efficiently 

collect these data from operators for all sites this year and in future years.

 1

U.S. Department of Transportation Pipeline and Hazardous Materials Safety 

Administration, Interim Final Rule: Pipeline Safety: Safety of Underground Natural Gas 

Storage Facilities, 81 Fed. Reg. 91,860 (Dec. 19, 2016) (codified at 49 C.F.R. parts 191 

and 192).

Appendix II: Number of Active Natural Gas 

Storage Sites as of January 2016 by State 

and Jurisdiction
Appendix II: Number of Active Natural Gas 

Storage Sites as of January 2016 by State and 

Jurisdiction

Page 34 GAO-18-89 Natural Gas Storage Safety

Table 3: Number of Active Natural Gas Storage Sites, by State and Jurisdiction, as 

of January 2016

State

Pre-PIPES Act 

jurisdiction

(federal or state)

Gas storage 

capacity

(billion cubic feet) Number of sites

Alaska federal a a

state 67.9 5

Alabama federal 11.2 1

state 22.0 1

Arkansas federal a a

state 12.2 2

California federal a a

state 375.5 14

Colorado federal 52.1 6

state 11.7 4

Iowa federal 90.3 4

state a a

Illinois federal 89.9 6

state 213.7 22

Indiana federal 5.0 4

state 28.6 17

Kansas federal 116.7 11

state 6.3 6

Kentucky federal 79.3 5

state 28.3 18

Louisiana federal 411.7 12

state 42.2 7

Maryland federal 18.3 1

state a a

Michigan federal 282.5 17

state 403.2 27

Minnesota federal a a

state 2.0 1

Mississippi federal 170.2 9

state 32.8 3

Missouri federal a a

state 6.0 1
Appendix II: Number of Active Natural Gas 

Storage Sites as of January 2016 by State and 

Jurisdiction

Page 35 GAO-18-89 Natural Gas Storage Safety

State

Pre-PIPES Act 

jurisdiction

(federal or state)

Gas storage 

capacity

(billion cubic feet) Number of sites

Montana federal 164.4 1

state 33.1 4

Nebraska federal 12.7 1

state a a

New Mexico federal 44.0 1

state 15.7 1

New York federal 123.4 24

state 3.5 2

Ohio federal 166.4 17

state 64.4 7

Oklahoma federal 103.7 5

state 87.7 8

Oregon federal a a

state 15.9 7

Pennsylvania federal 411.6 39

state 18.2 10

Tennessee federal a a

state 1.8 2

Texas federal 146.4 3

state 388.2 33

Utah federal 54.9 3

state a a

Virginia federal 4.0 1

state 1.4 1

Washington federal 24.6 1

state a a

West Virginia federal 253.3 27

state 6.0 4

Wyoming federal 68.8 5

state 4.9 4

Subtotal of sites by 

jurisdiction 

federal 2,905.5 204

state 1,893.1 211

Total 4,798.7 415

Source: Energy Information Administration and Pipeline and Hazardous Materials Safety Administration. | GAO-18-89

Note: A natural gas storage site is considered to be under federal jurisdiction—also known as 

“interstate”—if the site is linked to a federally-regulated interstate pipeline permitted by the Federal 

Energy Regulatory Commission; otherwise it is under state jurisdiction. Gas storage capacity refers to 
Appendix II: Number of Active Natural Gas 

Storage Sites as of January 2016 by State and 

Jurisdiction

Page 36 GAO-18-89 Natural Gas Storage Safety

“working gas capacity,” which the Energy Information Administration defines as the capacity of the 

volume of gas in the storage site that can be injected and withdrawn and is available to the 

marketplace. Gas storage capacity is displayed in billion cubic feet. For context, the United States 

uses about 26,600 billion cubic feet per year.

a

Indicates no natural gas storage site is present.
Appendix III: Comments from the Department 

of Transportation

Page 37 GAO-18-89 Natural Gas Storage Safety

Appendix III: Comments from the 

Department of Transportation
Appendix III: Comments from the Department 

of Transportation

Page 38 GAO-18-89 Natural Gas Storage Safety
Appendix IV: GAO Contacts and Staff 

Acknowledgments

Page 39 GAO-18-89 Natural Gas Storage Safety

J. Alfredo Gómez, (202) 512-3841 or gomezj@gao.gov

Frank Rusco, (202) 512-3841 or ruscof@gao.gov

In addition to the individuals named above, Mike Hix and Jon Ludwigson 

(Assistant Directors), Richard Burkard, Lee Carroll, Nirmal Chaudhary, 

Ellen Fried, Cindy Gilbert, Carol Henn, Mary Koenen, Jessica Lemke, 

Ben Licht, Greg Marchand, John Mingus, Katrina Pekar-Carpenter, Sara 

Sullivan, and Kiki Theodoropoulos made important contributions to this 

report.

Appendix IV: GAO Contacts and Staff 

Acknowledgments

GAO Contacts

Staff 

Acknowledgments

(101218)
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