April 2026 Issue
In This Issue
- RCP Adds Industry Leader John Gale as Executive Consultant
- URS Safety Alert: Virginia Pipeline Joining and Welding Issues
- URS Safety Alert: Virginia Electrical Expansion May Impact Pipeline Integrity
- PHMSA Seeks Public Input on Enforcement Procedures
- Q&A Section
- The Enforcement Corner
- Offshore Drilling Oversight Change
- Regulatory Watch: Key Dates & Deadlines
- Featured Service
- 2026 Conference News
- PSI Training Schedule
RCP Adds Industry Leader John Gale as Executive Consultant
RCP is pleased to welcome John Gale as an Executive Consultant. John joins RCP after a distinguished career with the U.S. Department of Transportation and Pipeline and Hazardous Materials Safety Administration, where he spent over 40 years, including 18 years with the Office of Pipeline Safety.
During his time at PHMSA, John served as Director of Standards, leading the planning, development, and management of pipeline safety regulations. His office also supported the regulatory agenda, oversaw the Pipeline Advisory Committees, and managed advisory bulletins and regulatory interpretations. He held this role since June 2008.
John now begins his next chapter supporting the industry and helping operators maintain safe, compliant pipeline systems.
A lifelong Washington, D.C. native, John now resides in Stafford, Virginia with his wife. He is the father of five sons and grandfather to seven. Outside of work, he enjoys golf, history, and following his favorite local sports teams.
Please join us in welcoming Mr. John Gale.
URS Safety Alert: Virginia Pipeline Joining and Welding Issues
A new safety alert highlights recurring issues observed during pipeline construction, inspections, and failure investigations across Virginia.
The focus is on pipeline joining and welding practices, where improper execution can create long-term integrity risks. Common issues include mitered plastic joints, inadequate ditch space for proper joining, and improper root bead welding practices such as “hinging” pipe, which is prohibited.
Additional concerns include incomplete scribing and scraping for electrofusion, poorly cut pipe ends, and incorrectly assembled mechanical joints using the wrong tools, parts, or torque specifications. These issues have been observed in multiple field settings, including tie-ins and transitions.
The alert emphasizes that even small mistakes during construction can lead to leaks years later. Following qualified joining and welding procedures is critical to ensuring long-term pipeline safety and compliance.
For a copy of the URS Safety Alert, please message Jessica Foley.
URS Safety Alert: Virginia Electrical Expansion May Impact Pipeline Integrity
A new safety alert from the Virginia State Corporation Commission highlights growing risks tied to expanding electrical infrastructure.
As electrical demand increases, utilities are adding new transmission lines, upgrading existing lines, and reconductoring systems to boost capacity. These changes can create AC interference when lines are near underground metallic pipelines, which can disrupt cathodic protection and accelerate corrosion.
The alert also notes that existing mitigation systems may not be designed for these upgraded conditions, increasing the risk of rapid pipeline degradation.
Operators are encouraged to take proactive steps, including:
- Coordinating with electric transmission operators early
- Monitoring VA811 excavation notices for nearby electrical work
- Increasing cathodic protection monitoring and interference testing
- Using routine patrols to identify changes in nearby electrical infrastructure
With large-scale electrical buildout underway, operators should stay engaged and monitor closely to prevent corrosion before it starts.
For a copy of the URS Safety Alert, please message Jessica Foley.
PHMSA Seeks Public Input on Enforcement Procedures
The Pipeline and Hazardous Materials Safety Administration (PHMSA) is opening the door for industry feedback on its enforcement process.
PHMSA’s Office of Pipeline Safety maintains a public document outlining its Section 4 Administrative Enforcement Processes. This resource walks through each step of an enforcement case, from initial action through final resolution.
For the first time, PHMSA is inviting stakeholders to formally review and comment on this process. The agency will accept feedback for 30 days at phmsaenforcement@dot.gov.
After the comment period, PHMSA plans to publish a redline version showing any updates. Comments that help support changes may also be made public.
This is a good opportunity for operators and industry professionals to help shape how enforcement is carried out moving forward.
Q&A Section
Do you have questions? RCP’s SMEs have the answers. Information will be posted here for questions we often get from clients or discussions we have with regulators regarding interpretations and pending regulatory deadlines.
Q: The proposed PHMSA language states that we still have to do a post-construction coating check within 6 months. It just moved the “start date” of that 6 months from “backfill” to “in-service date.” It doesn’t look like we can avoid the coating check after construction. Check the proposed language of 192.319(d).
A: Yes, you still have to do a coating evaluation but it’s from in-service, not the date the line was buried.
Ask the Experts
Do you have a question for the experts at RCP? Submit your question using this form. If your question is selected for a future newsletter, you will be eligible for a gift of your choice from RCP’s online Store.
Upcoming Deadlines:
- The deadline to submit written comments in response to PHMSA’s forthcoming NPRM on Pipeline Safety: Safety of Gas Distribution Pipeline and Other Pipeline Safety Initiatives will be 60 days from the date of publication in the Federal Register. Comments may be filed at https://www.regulations.gov/ Docket No. PHMSA-2021-0046.
- And as a reminder, the “Stay of Enforcement” does not mean regulators don’t expect work toward getting compliance activities in place can be ignored.
If we can help, contact Jessica Foley.
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 March 2026, PHMSA issued 7 NOAs, 8 NOPVs, and 7 WLs accompanied by $494,700 in proposed fines.
- $63,300 – § 195.452(b)(2) – Integrity Management
- $137,700 – § 195. 452(i)(1) – Preventive & Mitigative Measures
- $114,900 – § 192.12(b)(2) – Underground Natural Gas Storage
- $48,700 – § 192.12(c) – Procedure Manual
- $39,400 – § 192.461(a)(1) – External Protective Coating
- $36,800 – § 192.805(b) – Operator Qualification
- $53,900 – § 195.452(j)(3) – Assessment Intervals
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.
Offshore Drilling Oversight Change
The U.S. Interior Department plans to merge two offshore drilling regulators, a shift from reforms made after the Deepwater Horizon oil spill.
Officials say the move will streamline permitting and improve coordination. Critics argue it could weaken independent safety oversight and reintroduce risks that led to the 2010 disaster.
The decision reflects the ongoing balance between expanding energy development and maintaining strong environmental and safety protections. (Source: AP News)
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: Underground Gas Storage
RCP has earned a worldwide reputation for providing professional engineering services and regulatory expertise to oil and gas operators, including underground gas storage in depleted reservoirs, aquifers and salt caverns.
We have the RESOURCES, SOFTWARE and the KNOWLEDGE to assist clients with building, implementing, and improving comprehensive operational integrity management programs in response to the PHMSA rule incorporating API RP 1171/1170 v2 (Jan. 1st, 2026) on underground gas storage.
Experienced Resources
- Highly respected underground storage industry & risk management SMEs
- Professional engineering support
- Knowledgeable technical standards developers
- Regulatory expertise
Asset Management Tools
- Gap assessment protocols
- Comprehensive risk analysis program through software
- Out-of-the-box risk model designed by RCP SMEs
- Operator-specific risk models
- Full-featured workflow & asset management software
- Track, verify and complete all work done on a well
- Wellsite/valve inspections, annulus pressure, well logging, well swabbing, capital projects, etc.
Gap Analysis/Effective Evaluation
- PHMSA Final Rule: Safety of Underground Natural Gas Storage
- API RP 1171/1170 v2
- PHMSA Advisory Bulletins
- State-Specific Regulations
Process Development and Continuous Improvement
- Storage risk management plan
- Site-specific operations & integrity standards
- Key performance indicators
Risk Analysis Model
- API RP 1171 v2, Section 8
- Out-of-the-box risk model designed by RCP SMEs
- Configurable to client and/or state needs
- Separate models for depleted reservoirs and caverns
- Deterministic Approach
- SME/Documentation
- Data (ex. Well Log)
- Captures documents used in risk analysis and sub-surface safety valve assessment tools
- Customizable queries & reporting, including a fully revamped risk analysis dashboard experience to easily see what the risk model is trying to tell you
Asset Integrity Assessment & Remediation Progress Tracking
- Asset change management
- Traceable, verifiable, and complete record management
- Audit-ready software
- Schedule and progress reporting
- Integrity assessment and repairs
- Regulatory inspections
- Preventative Maintenance
- Capital Projects
- Well Logging
- Data capture & analysis
- Data trends for all the inspection data you are capturing
- Data overlays to help make better, actionable decisions
- Well log comparison (ex. corrosion rate)
- Documentation linkage to work activity
2026 Conference News
NGA Spring Operations Conference 2026
April 21-22, 2026 | Saratoga Hilton | Saratoga Springs, NY
This operations-related conference helps to address current issues, from workplace safety to new technology applications. The 2026 Conference will include sessions on damage prevention, emissions reductions, emerging fuels and technology, and many other relevant topics. In addition, there will be general sessions with industry leaders focused on the future of the natural gas industry.
Click here to register for the NGA Spring Operations Conference.
Speaker Announcement
RCP is proud to have Mr. Chris McLaren on panel to discuss “Pipeline Safety Regulatory Intent – Trusted to Work Responsibly” at the upcoming Northeast Gas Association Spring Operations Conference in Saratoga Springs, NY!
AGA Operations Conference & Committee Meetings Spring 2026
April 26-30, 2026 | JW Marriott Tampa Water Street | Tampa, FL
The Operations Conference is the natural gas industry’s premier gathering of operators of natural gas delivery systems and service and equipment providers. Developed by gas operators for gas operators, this event is the industry’s largest annual forum with more than 800 operations management in attendance. The event offers technical sessions with topics including but not limited to gas measurement, pipeline integrity, operations advocacy, workforce safety, environment, storage, engineering, construction and maintenance, gas control, corrosion control, and damage prevention. Attendees share technical knowledge and leadership strategies, and learning events promote the safe, reliable delivery of natural gas and the safety of the workforce.
Click here to register for the AGA Operations Conference.
API Pipeline Conference 2026
April 27-29, 2026 | Gaylord Rockies Resort & Convention Center | Aurora, CO
Join more than 1,000 natural gas professionals in Aurora, Colorado, April 27–29, 2026, for three days of collaboration, learning, and industry insight.
As the energy landscape continues to evolve, the oil and gas industry faces a dual challenge: meeting global energy demand safely and responsibly while advancing toward a lower-carbon future. Our industry’s expertise, infrastructure, and commitment to safety remain critical to building a resilient and sustainable energy system.
Join peers from across the industry as we share ideas, strengthen partnerships, and continue working toward a practical and profitable energy future.
Click here to register for the API Pipeline Conference.
We’re Exhibiting!
Stop by booth #518 to say hi, grab some swag, and talk pipeline integrity with our team. Mr. William Byrd and Mr. Chris McLaren will be on-site to answer any questions. We’d love to connect in person.
TGA Annual Operations & Management Conference 2026
June 1-4, 2026 | Moody Gardens | Galveston, TX
The Texas Gas Association (TGA) Annual Operations & Management Conference in Galveston brings together natural gas operators, engineers, regulators, and service providers from across Texas and the surrounding region to share knowledge on pipeline operations, safety, maintenance, and regulatory compliance. The event features technical presentations, panel discussions, and networking opportunities focused on improving system reliability, operational efficiency, and safety across the natural gas industry.
Click here to register for the TGA Annual Operations & Management Conference
We’re Speaking and Exhibiting!
Mr. Chris McLaren will be presenting “A Fair Price: Gas Distribution Rates Supported by Risk Analysis.”
Stop by booth #45 to chat with Mr. Chris McLaren &
Ms. Jessica Foley!
Texas RRC Regulatory Conference
July 13-15, 2026 | Kalahari Resorts & Conventions | Round Rock, TX
The Railroad Commission of Texas invites you to our premier three-day training event—the definitive resource for navigating Texas energy regulations, procedures and processes. Gain expert guidance on the laws and procedures affecting hydrocarbon production, pipeline safety and critical infrastructure. Plus, this year we are offering sessions specifically focusing on Alternative Fuels Safety and Surface Mining and Reclamation. Don’t miss this opportunity, click here to register today!
We’re Speaking and Exhibiting!
Mr. Mike LaMont will be presenting “Confirmation Bias Lessons Learned from Conducting Incident/Accident Investigations”
Mr. Chris McLaren will be presenting “Pipeline Safety Regulatory Focus Areas”
Stop by our booth to chat with Mr. Mike LaMont, Mr. Chris McLaren, Ms. Jessica Foley &
Mr. Chris Foley!
PSI Training Schedule
|
DATE |
COURSE | FEE |
|
May 19-21, 2026 |
Advanced DOT Pipeline Compliance Workshop (49 CFR 192 & 195) |
$2,150 |
|
August 4-6, 2026 |
DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 & 199) |
$2,150 |
| On-Demand |
DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 & 199) |
$2,150 |
| On-Demand |
Fundamentals of Pipeline Pressure Testing (Gas & Liquid Pipelines) |
$1,200 |
WEBINAR RECORDING
Pipeline Safety: Unpacking the Class Location Change Requirements
Thank you to everyone who attended and participated in this informative webinar. The session recording is posted to our YouTube channel. Please watch, like, and subscribe to our channel!
You asked and we listened!
Advanced DOT Pipeline Compliance Workshop is on the calendar!
This intensive and interactive 3-day, in-person workshop is designed for those who have previously completed our DOT Pipeline Compliance Workshop and are ready to take their knowledge to the next level.
New Workshop Alert!
Prepare Your Team for Pipeline Safety Audits with Confidence!
Our 3-day Pipeline Safety Audit Workshop is tailored for professionals responsible for the safe operation of hazardous liquid and natural gas pipelines. Designed for groups of 10-15 participants, this interactive training…
On-Site Training Request
We have conducted on-site training for oil and gas companies for over 25 years and can provide customized workshops for companies with groups of five or more.
We would welcome the opportunity to discuss our services with you.
Sincerely,
W. R. (Bill) Byrd, PE
President
RCP Inc.