October 2025 Issue
In This Issue
PHMSA Issues 21 Notices
On October 2nd, PHMSA has issued twenty-one notices related to a prior set of notices that were issued on July 1, 2025. Most of these are either withdrawals of Direct Final Rules or are confirming effective dates of recent industry standards to be incorporated by reference into Parts 192 and 195. There is also a public meeting announcement for pending LNG regulations.
- Adjust Annual Report Filing Timelines (Withdrawal of DFR)
Due to the receipt of adverse comment(s), PHMSA is withdrawing the Direct Final Rule (DFR) titled “Adjust Annual Report Filing Timelines,” which published on July 1, 2025. Effective October 2, 2025, PHMSA withdraws the DFR published at 90 FR 28047 on July 1, 2025. The original DFR extended the deadline for submitting annual reports for operators of gas distribution pipelines, gas transmission pipelines, regulated gas gathering pipelines, Type R gas gathering lines, underground natural gas storage facilities, and liquefied natural gas facilities to June 15th. The annual reporting deadline for these pipelines will revert back to March 15th for the previous calendar year.
- Integration of Innovative Remote Sensing Technologies for Right-of-Way Patrols on Gas and Hazardous Liquid Pipelines (Withdrawal of DFR)
Due to the receipt of adverse comment, PHMSA is withdrawing the DFR titled “Integration of Innovative Remote Sensing Technologies for Right-of Way Patrols on Gas and Hazardous Liquid Pipelines,” which published on July 1, 2025. Effective October 2, 2025, PHMSA withdraws the DFR published at 90 FR 28105 on July 1, 2025. That DFR clarified that PHMSA’s right-of-way patrol requirements were technology neutral, and that remote sensing technologies, such as unmanned aerial systems and satellites, could be used for compliance purposes.
- Property Damage Definition for Incident Reporting on Gas Pipelines and Accidents on Hazardous Liquid Pipelines (Withdrawal of Direct Final Rule)
Due to the receipt of adverse comment, PHMSA is withdrawing the DFR titled “Property Damage Definition for Incident Reporting on Gas Pipelines and Accidents on Hazardous Liquid Pipelines,” which published on July 1, 2025 (90 FR 28050). PHMSA may incorporate the adverse comment into a subsequent DFR or may publish a notice of proposed rulemaking (NPRM). An NPRM would provide an opportunity for public comment. In the original DFR, PHMSA amended the definition of an incident on a gas pipeline, the calculation of property damage to exclude the costs associated with removing and replacing pavement and certain other inconsequential costs. PHMSA also updated the monetary damages threshold for accident reporting on hazardous liquid pipelines to align with an inflation-adjusted formula specified in its regulations governing gas pipeline incident reporting.
- Rationalize Calculation of Regulatory Filing and Compliance Deadlines (DFR; confirmation of effective date)
PHMSA is amending pipeline safety regulations to introduce a clarification that filing and compliance deadlines falling on weekends and Federal holidays will be adjusted automatically to the following business day. The effective date of the DFR published July 1, 2025 (90 FR 28044), is updated from October 9, 2025, to November 3, 2025.
- PHMSA issues DFR confirming effective dates of January 1, 2026 for the following industry standards to be incorporated by reference into Parts 192 and 195.
- API RP 1170 and API RP 1171, 2nd edition
- API Specification 6D, Specification for Valves to the 25th edition (issued in November 1, 2021)
- API Standard 620, “Design and Construction of Large, Welded, Low-Pressure Storage Tanks” to the 12th edition, October 2013, including Addendum 1 through 4 (November 2014 through February 2025) and Errata 1 (March 2025), (collectively, API STD 620)
- ASTM A381/A381M, “Standard Specification for Metal-Arc-Welded Carbon or High-Strength Low-Alloy Steel Pipe for Use with High-Pressure Transmission System”, 2023 edition
- ASTM A578/A578M, “Standard Specification for Straight-Beam Ultrasonic Examination of Rolled Steel Plates for Special Applications”, 2017 edition (reapproved 2023)
- ASTM F1973, “Standard Specification for Factory Assembled Anodeless Risers and Transition Fittings in Polyethylene (PE) and Polyamide 11 (PA11) and Polyamide 12 (PA12) Fuel Gas Distribution Systems”, 2021 edition
- ASTM F2145, “Standard Specification for Polyamide 11 (PA 11) and Polyamide 12 (PA12) Mechanical Fittings for Use on Outside Diameter Controlled Polyamide 11 and Polyamide 12 Pipe and Tubing”, 2023 edition
- ASTM F2600, “Standard Specification for Electrofusion Type Polyamide-11 Fittings for Outside Diameter Controlled Polyamide-11 Pipe and Tubing”, 2023 edition
- ASTM F2767, “Specification for Electrofusion Type Polyamide-12 Fittings for Outside Diameter Controlled Polyamide-12 Pipe and Tubing for Gas Distribution”, 2023 edition
- ASTM F2817, “Standard Specification for Poly (Vinyl Chloride) (PVC) Gas Pressure Pipe and Fittings for Maintenance or Repair”, 2023 edition
- ASTM F2945, “Standard Specification for Polyamide 11 Gas Pressure Pipe, Tubing, and Fittings”, 2023 edition
- NFPA 70, “National Electrical Code (NEC)”, 2023 edition
- PPI TR-4, “PPI HSB Listing of Hydrostatic Design Basis (HDB), Hydrostatic Design Stress (HDS), Strength Design Basis (SDS), Pressure Design Basis (PDB) and Minimum Required Strength (MRS) Ratings For Thermoplastic Piping Materials or Pipe”, 2024 edition
- PPI TR-3, “Policies and Procedures for Developing Hydrostatic Design Basis (HDB), Hydrostatic Design Stresses (HDS), Pressure Design Basis (PDB), Strength Design Basis (SDB), Minimum Required Strength (MRS) Ratings, and Categorized Required Strength (CRS) for Thermoplastic Piping Materials or Pipe”, 2024 edition
- API RP 2026, “Safe Access/Egress Involving Floating Roofs of Storage Tanks in Petroleum Service”, 4th edition
- ASTM A53/A53M, “Standard Specification for Pipe, Steel, Black and Hot-Dipped, Zinc-Coated, Welded and Seamless”, 2022 edition
- Liquefied Natural Gas Facilities Public Meeting 2025
PHMSA will conduct a virtual public meeting on October 22, 2025 to discuss pending proposed rulemaking for LNG facilities, regulated under Part 193. The meeting agenda and instructions on how to attend virtually will be published once they are finalized on the public meeting web page at: https://primis-meetings.phmsa.dot.gov/.
PHMSA Adopts Version 2 of API RP 1170 and 1171, Underground Gas Storage
PHMSA has confirmed that the 2nd editions of API RP 1170 and 1171 will be incorporated by reference into Part 192, effective January 1, 2026.
- API RP 1170 Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage
- API RP 1171 Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs
RCP’s underground gas storage team includes several industry veterans, including Steve Nowaczewski, Rick Gentges, and Phil Baker and a dedicated storage integrity TaskOp Team. RCP serves over 60% of the underground gas storage working gas capacity in the United States, and growing. There are several significant changes from editions 1 to 2 in both RP’s as depicted below. RCP’s underground gas storage clients utilize our team to further enhance their reservoir/cavern and well integrity programs. TaskOp has proven to be an industry accepted, off the shelf, user friendly, customizable platform for hosting storage operator’s critical data. Some important features include:
- Risk analysis, compliant with RP 1170/1171 edition 2
- Electronic well files
- Event tracking
- Well site visit inspection e-forms, including offline mobile capability
- Primary data repository
- Data extraction
- Abnormal Operating Condition alerts
- Daily reporting
- Integration with other database programs
RCP’s underground gas storage team has completed a detailed comparison of both editions of API RP 1170 and 1171. For API 1171 the net change in shall/should is approximately as follows:
| 1st edition shall = 120 | 2nd edition shall = 151 |
| 1st edition should = 254 | 2nd edition should = 242 |
For more information about RCP’s underground gas storage capabilities, contact jfoley@rcp.com.
Regulatory Watch: Key Dates & Deadlines
Welcome to Regulatory Watch! In this monthly update, we’ll keep you informed on proposed rule comment periods, effective dates, and upcoming deadlines for various compliance requirements.
Have questions about an upcoming deadline? Please reach out to Jessica Foley for assistance!
Featured Service
TaskOp Highlight: MOC Module
TaskOp, RCP’s reliable Workflow & Asset Management Application, features a fully integrated Management of Change (MOC) module. Designed to meet the requirements of 49 CFR 192, 195, and PHMSA’s RIN2, Gas Mega Rule regulations as documented in § 192.13, this module allows users to electronically oversee their company’s management of change process.
TaskOp’s MOC module was built to manage the following aspects of any MOC process:
- Scalable approval process, with designated alternates
- Tracking of MOCs through a step-by-step process flow
- Set automatic notifications to key personnel for each process step
- Allows MOC Coordinator to track real time updates and progress of MOC
- Provides checks and balances for modifications of process to ensure MOC security
- Comprehensive documentation of change (TVC)
TaskOp’s MOC module was specifically designed to provide ease of use while being flexible and scalable, offering robust customization options to meet increasing regulatory requirements. This module ensures a consistent and reliable experience throughout any MOC process.
If your goal is a streamlined and accessible MOC process, look no further than TaskOp’s MOC module.
From 49 CFR 192.13: “For pipeline segments other than those covered in subpart O of this part, this management of change process must be implemented by February 26, 2024. The requirements of this paragraph (d) do not apply to gas gathering pipelines.”
To learn more about the TaskOp MOC module, click the link below to schedule a demo.
The Enforcement Corner
The Enforcement Corner summarizes recent PHMSA enforcement actions, indicating where PHMSA is putting its enforcement efforts and the fines they are proposing for various types of violations.
In August 2025, PHMSA issued 3 NOAs, 5 NOPVs, and 4 WLs accompanied by $152,600 in proposed fines.
- $37,200 §192.229(c)(1) Welders & Welding Operators
- $115,400 §192.739(a) Pressure Limiting & Regulating Stations
Please note:
- Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA.
- Proposed Civil Penalties (PCP) may be reduced or eliminated before an enforcement action becomes final.
- A Corrective Action Order (CAO) usually addresses urgent situations arising out of an accident, spill, or other significant, immediate, or imminent safety or environmental concerns.
- A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements.
- A Notice of Proposed Safety Order (PSO) addresses pipeline integrity risks that may not constitute a hazardous facility requiring immediate corrective action (see Corrective Action Order described above), but do need to be addressed over time.
- A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred.
- Proposed Compliance Orders (PCO) frequently document actions the pipeline operator already planned to do.
- Warning Letter (WL) is an official notice by PHMSA that an operator needs to make improvements but that no further enforcement is proposed for those findings at this time.
RCP maintains a detailed database of all PHMSA enforcement actions dating back to 2007 and is routinely asked for data analysis of various enforcement actions. For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.
Need to respond to a PHMSA enforcement action?
Need to know if your enforcement action is an outlier, or par for the course?
RCP maintains a detailed database of all PHMSA enforcement actions and their resolution which enables us to compare and contrast individual enforcement actions to nationwide actions and trends. We can help put things into context to ensure an effective reply for each citation. For more information on how RCP can assist with enforcement action data analysis services, contact Jessica Foley.
Did You Know?
Did You Know? RCP’s Version 2.0 of its TaskOp Underground Storage Reservoir Risk Module is officially live!
Developed in response to the release of API 1171’s 2nd Edition, RCP has added a number of new, premium features, including robust threat interaction tables, to enable users to comply with the new recommended practices being introduced.
Click here to learn more.
2025 Conference News
APGA Operations Conference 2025
October 21-October 23, 2025 | Sheraton Hotel Charlotte | Charlotte, NC
This event typically attracts over 250 natural gas distribution industry professionals from more than 70 public gas systems to learn about topics such as PHMSA’s Natural Gas Distribution Infrastructure Safety and Modernization Grant Program, methane emission mitigation strategies, and new technology along with an exhibitor hall.
Click here to register for APGA’s Operations Conference.
Pipeline Safety Institute
Welcome to the Pipeline Safety Institute – your one-stop destination for pipeline compliance training. Whether you are new to the industry, an experienced oil & gas professional that needs a refresher, or you want to take a deep dive into the latest regulation changes, you have come to the right place.
Training topics cover pipeline operations and engineering concepts, with future course offerings for Integrity Management programs, including ILI, material testing, fitting and component selection, and qualifying welders. Our curriculum continues to grow to meet the changes and challenges in the energy industry.
The Pipeline Safety Institute has a team of experienced instructors and subject matter experts from all disciplines. With over 25 years of training experience, we are committed to providing the best pipeline safety training in the industry. Click Here to see PSI’s available courses.
We would welcome the opportunity to discuss our services with you.
Sincerely,
W. R. (Bill) Byrd, PE
President
RCP Inc.