June 2026 Issue
In This Issue
- The Enforcement Corner
- PHMSA Proposes Updates to Breakout Tank Inspection Requirements
- PHMSA Names Thomas Correll as Associate Administrator for Pipeline Safety
- PHMSA Clarifies MAOP Restoration Timeline Under Class Location Change Rule
- Featured Service
- Regulatory Watch: Key Dates & Deadlines
- 2026 Conference News
- PSI Training Schedule
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 May 2026, PHMSA issued 1 CAO, 3 NOA, 6 NOPVs, and 4 WLs accompanied by $673,930 in proposed fines.
- $62,900 – § 195.402(c)(12) – Procedure Manual
- $53,900 – § 195.420(a) – Valve Maintenance
- $25,100 – § 195.452(h)(4)(iii)(B) – Evaluation & Remediation
- $266,015 – § 195.402(a) – Procedure Manual
- $266,015 – § 195.422(a) – Pipeline Repairs
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.
PHMSA Proposes Updates to Breakout Tank Inspection Requirements
[Docket No. PHMSA-2025-1271]
PHMSA has published a Notice of Proposed Rulemaking (NPRM) that would update the agency’s breakout tank inspection regulations under 49 CFR Part 195. The proposal would incorporate the 5th Edition of API Standard 653, replacing the currently referenced 3rd Edition, and would authorize operators to use Risk-Based Inspection (RBI) procedures when establishing inspection intervals for in-service breakout tanks.
A key feature of the proposal is the ability for operators to extend internal inspection intervals based on a documented RBI assessment. PHMSA is proposing a maximum interval of 20 years for an initial internal inspection and 25 years for subsequent inspections when supported by an RBI analysis. Operators choosing this approach would be required to maintain records supporting the assessment and identify RBI-managed tanks in annual reporting and NPMS submissions.
PHMSA estimates the proposed changes could save the industry between approximately $25 million and $150 million annually by reducing unnecessary internal inspections while maintaining safety through risk-informed decision-making. The agency is accepting comments on the proposal for 60 days following publication in the Federal Register.
Please message Jessica Foley for a copy of this NPRM.
Expert Insight from John Gale, Senior Executive Consultant
RCP’s SME Mr. John Gale provides his insight on this rule change:
“PHMSA isn’t slowing down on storage tank oversight.
In this rulemaking, PHMSA is proposing to update Part 195 to incorporate the 5th Edition of API Standard 653 for breakout tanks. The agency is also proposing revisions to §195.432 that would formally authorize the use of Risk-Based Inspection (RBI) procedures to establish inspection intervals for in-service breakout tanks.
For operators, this signals continued movement toward modern risk management practices. Incorporating API 653 (5th Edition) aligns federal regulations with current industry standards, while RBI flexibility could allow operators to tailor inspection intervals based on actual risk, not just fixed timelines.
If adopted as proposed, these updates could have practical implications for inspection planning, documentation, and integrity programs. Now is the time to evaluate how your breakout tank program aligns with API 653 (5th Edition) and whether RBI methodologies are ready to support compliance under Part 195.”
PHMSA Names Thomas Correll as Associate Administrator for Pipeline Safety
PHMSA has named Thomas (Tom) Correll as its new Associate Administrator for Pipeline Safety. Correll brings more than 30 years of experience in pipeline safety, integrity management, environmental compliance, and risk management.
Prior to joining PHMSA, Correll served as Vice President of Pipeline Safety and Risk at Northern Natural Gas, where he led compliance and integrity management programs for a major interstate natural gas pipeline system. His experience includes PHMSA compliance, environmental permitting, engineering oversight, and large-scale infrastructure projects.
Correll’s appointment places an experienced pipeline industry leader at the helm of PHMSA’s pipeline safety program. Operators will be watching closely to see how his extensive background in pipeline operations and regulatory compliance influences the agency’s future priorities and initiatives.
Click here to access the official announcement from PHMSA.
PHMSA Clarifies MAOP Restoration Timeline Under Class Location Change Rule
[Docket No. PHMSA-2017-0151]
PHMSA has issued a technical correction to its January 14, 2026, final rule on Class Location Change requirements in 49 CFR §192.611.
The original rule allows operators to use an Integrity Management (IM) alternative to confirm or restore Maximum Allowable Operating Pressure (MAOP) on eligible gas transmission pipeline segments impacted by a class location change.
This latest action does not change the rule. It simply clarifies when the 24-month compliance timeline begins for MAOP restorations.
What Changed?
For operators restoring MAOP under the IM alternative, PHMSA confirms that the 24-month deadline runs from:
- The effective date of the final rule, or
- The date the operator decides to initiate the MAOP restoration,
whichever is later.
The correction makes clear that the decision date to restore MAOP is treated as the class location change date for purposes of starting the compliance clock.
Why This Matters for Pipeline Operators
This clarification removes ambiguity for both engineering and compliance teams.
If a Class 3 gas transmission segment was previously pressure-reduced due to a class location change, and you are now considering restoring MAOP using the IM alternative:
- Your 24-month window starts when you formally decide to move forward with restoration (if later than the rule’s effective date).
- There are no new technical requirements.
- PHMSA confirms there are no additional compliance costs.
Practical Takeaway
For operators managing gas transmission pipelines, MAOP restoration, and integrity management programs, documentation matters.
Make sure your internal records clearly establish the date the MAOP restoration decision is made. That date now drives your compliance timeline under §192.611.
This correction provides regulatory clarity—not new obligations—but it reinforces the importance of coordination between engineering, regulatory, and administrative teams when planning MAOP restoration activities.
Please message Jessica Foley for a copy of this rule change.
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
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.
Sprint I
To further the Administration’s deregulatory policies, PHMSA has published in today’s Federal Register twenty-eight (28) separate rulemaking actions affecting the pipeline safety regulations (PSR; Parts 190-199). Click here to access the documents.
| Pipeline Safety: Rationalize Special Permit Conditions | PHMSA proposes to amend its special permit procedures to ensure permit conditions are directly tied to the specific pipeline safety regulations being waived. | NPRM | 49 CFR Part 190 |
| Pipeline Safety: Rationalize Calculation of Regulatory Filing and Compliance Deadlines | PHMSA will clarify that regulatory filing and compliance deadlines falling on weekends or Federal holidays automatically move to the next business day. | DFR | 49 CFR Part 190 |
| Pipeline Safety: Adjust Annual Report Filing Timelines | PHMSA will amend annual reporting requirements to move the gas pipeline annual report submission deadline from March to June. | DFR | 49 CFR Part 191 |
| Pipeline Safety: Property Damage Definition for Incident Reporting | PHMSA will clarify incident reporting property damage calculations for gas pipelines and update hazardous liquid accident reporting thresholds using inflation-adjusted criteria. | DFR | 49 CFR Parts 191 & 195 |
| Pipeline Safety: Exception for In-Plant Piping Systems | PHMSA proposes to clarify that in-plant piping systems are not subject to federal pipeline safety regulations. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Codify Enforcement Discretion on Incidental Gathering Lines | PHMSA proposes to codify enforcement discretion clarifying that restrictions on the historical incidental gathering line exemption apply only to newly constructed lines. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Eliminate Burdensome Coating Assessment Deadlines | PHMSA proposes to replace prescriptive deadlines for coating damage assessments and remediation with a requirement that activities be completed before the pipeline is placed in service. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Atmospheric Corrosion Reassessment for Pipeline Replacements | PHMSA proposes to remove the 3-year reassessment interval following replacement of atmospheric corrosion defects and allow use of the standard 5-year reassessment interval. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Harmonize Class Change Pressure Test Requirements | PHMSA proposes to reduce the minimum pressure test duration following certain class location changes from 8 hours to 4 hours, aligning with existing Subpart J requirements. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Clarify MAOP Reconfirmation Testing Records | PHMSA will issue a technical correction clarifying that operators may use pre-1970s pressure test records when reconfirming MAOP under §192.624. | Final Rule | 49 CFR Part 192 |
| Pipeline Safety: Remote Sensing Technologies for ROW Patrols | PHMSA will explicitly allow right-of-way patrols to be conducted using unmanned aircraft systems, satellites, and other remote sensing technologies. | DFR | 49 CFR Parts 192 & 195 |
| Pipeline Safety: Technical Standards Updates and Amendments | PHMSA will update incorporated standards and make technical amendments in response to an industry petition for reconsideration. | Final Rule | 49 CFR Part 192 |
| Pipeline Safety Program: Update of Standards Incorporated by Reference | PHMSA issued multiple direct final rules updating incorporated industry consensus standards used throughout Parts 192 and 195, replacing outdated editions with current versions. | Multiple DFRs | 49 CFR Parts 192 & 195 |
Sprint II
The following is a summary of the 40 rulemakings that PHMSA published in the Federal Register on April 24, 2026. A hyperlink has been provided to each rule. If any adverse comment is received to a DFR PHMSA must rescind the rule and repropose.
| Pipeline Safety and Hazardous Materials Safety: Amendments to PHMSA Procedural Regulations | PHMSA proposed miscellaneous amendments to procedural regulations governing informal rulemaking for both pipeline safety and hazardous materials programs. | NPRM | 49 CFR Part 190 |
| Pipeline Safety: Interpretation Request Procedures | PHMSA amended interpretation procedures to require publication of interpretation requests on its website and provide an opportunity for public comment. | Final Rule | 49 CFR Part 190 |
| Pipeline Safety: Declaratory Order Procedures | PHMSA established formal procedures for issuing declaratory orders through a new section in Part 190. | Final Rule | 49 CFR Part 190 |
| Pipeline Safety: Consent Orders | PHMSA clarified that consent agreements may be used to resolve enforcement actions, including cases involving civil penalties. | Final Rule | 49 CFR Part 190 |
| Pipeline Safety: Adjustment to OPID Notifications for Construction | PHMSA proposed adjusting the inflation-based threshold that triggers OPID notifications for certain construction and facility modification activities. | NPRM | 49 CFR Part 191 |
| Pipeline Safety: Eliminating Limitations on Welders and Welding Operators | PHMSA proposed allowing welders qualified through non-destructive testing methods to perform compressor station welding activities currently subject to additional restrictions. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Material Properties Verification During MAOP Reconfirmation | PHMSA proposed clarifying that material testing at pressure test manifold sites is not required when traceable, verifiable, and complete material records already exist. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Electronic Retention of Part 194 Response Plans | PHMSA amended regulations to allow operators to maintain electronic copies of response plans instead of paper copies. | DFR | 49 CFR Part 194 |
| Pipeline Safety: Remote Monitoring of Rectifiers | PHMSA proposed allowing remote monitoring technologies for rectifiers used in external corrosion control programs. | NPRM | 49 CFR Part 195 |
| Pipeline Safety: Clarifying Hazardous Liquid High-Consequence Area Designations | PHMSA amended HCA guidance to clarify spill considerations in agricultural fields and reorganize threat identification guidance. | DFR | 49 CFR Part 195 |
| Pipeline Safety: Timeframe to Make Rupture-Mitigation Valves Operational | PHMSA proposed extending the deadline for placing rupture-mitigation valves into operation from 14 days to 90 days after a pipeline enters service. | NPRM | 49 CFR Part 192 |
| Pipeline Safety: Hazardous Liquid Valve Maintenance Schedule | PHMSA proposed allowing operators to implement risk-based valve maintenance schedules, subject to a maximum inspection interval of one year. | NPRM | 49 CFR Part 195 |
| Pipeline Safety: Property Damage Definition for Incident Reporting | PHMSA proposes revising property damage thresholds for reportable gas and hazardous liquid pipeline incidents and clarifying applicability to telephonic notifications. | NPRM | 49 CFR Parts 192 & 195 |
| Pipeline Safety: Remote Sensing Technologies for ROW Patrols | PHMSA proposes clarifying that unmanned aerial systems, satellites, and other remote-sensing technologies may be used to satisfy right-of-way patrol requirements. | NPRM | 49 CFR Parts 192 & 195 |
| Pipeline Safety: Adjust Annual Report and NPMS Filing Timelines | PHMSA proposes extending annual report and NPMS submission deadlines for gas pipeline and storage operators to June 15 each year. | NPRM | 49 CFR Part 191 |
| Pipeline Safety: Editorial Corrections and Clarifications | PHMSA issued multiple final rules correcting editorial errors, updating references, removing obsolete submission methods, and improving regulatory clarity. | Final Rules | Various |
| Pipeline Safety: Update of Standards Incorporated by Reference | PHMSA issued multiple direct final rules updating incorporated industry consensus standards, including NFPA, ASTM, MSS, NACE, and ASME standards. | Multiple DFRs | 49 CFR Parts 192 & 195 |
Have questions about an upcoming deadline? Please reach out to Jessica Foley for assistance!
2026 Conference News
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!
FEPA Summer Symposium 2026
July 14-16, 2026 | Hawks Cay Resort | Key West, FL
The Florida Emergency Preparedness Association (FEPA) Summer Symposium 2026 brings together emergency management professionals from across Florida to exchange knowledge, discuss emerging challenges, and strengthen coordination among public and private sector stakeholders. The event provides attendees with opportunities for professional development, networking, and collaboration on topics that support community resilience, disaster preparedness, response, and recovery efforts.
Click here to register for this event.
We’re Exhibiting!
Stop by the booth to visit with Mr. Rhett Krieger!
AGA Strengthening Contractor Partnerships in Gas Construction Ops Workshop
August 4-5, 2026 | GTI Energy Headquarters | Des Plaines, IL
The AGA’s Strengthening Contractor Partnerships in Gas Construction Operations Workshop, hosted at GTI Energy, is a collaborative, in-person workshop designed to bring together natural gas utilities, construction contractors, and industry leaders to advance contractor performance, safety culture, and operational excellence. This interactive workshop will focus on strengthening the working relationship between operators and their contractors, with an emphasis on improving communication, aligning expectations, and sharing leading practices that enhance construction quality, workforce competency, and overall project outcomes. Participants will engage in facilitated discussions, peer-to-peer knowledge exchange, and practical sessions addressing key challenges facing today’s gas construction environment, including contractor oversight, workforce considerations, safety performance, and field execution.
Click here to register for this event.
We’re Sponsoring!
Join us on-site where Chris Foley will be demonstrating TestApp and showcasing how it streamlines pressure testing with real-time data collection, analysis, and reporting.
LGA Pipeline Safety Conference
August 10-13, 2026 | Hilton New Orleans Riverside | New Orleans, LA
The Louisiana Gas Association (LGA) Pipeline Safety Conference is one of the premier pipeline safety events in the country, bringing together pipeline operators, regulators, consultants, and industry service providers to discuss the latest regulatory developments, safety initiatives, operational challenges, and emerging technologies. The conference features multiple days of educational sessions, networking opportunities, exhibitor engagement, and presentations from industry leaders focused on improving pipeline safety and compliance. Held August 10–13, 2026, at the Hilton Riverside in New Orleans, the event provides attendees with valuable insights into current pipeline safety issues and best practices across the natural gas industry.
Click here to register for this event.
We’re Exhibiting & Speaking!
Join RCP at the Louisiana Gas Association Pipeline Safety Conference. Chris Foley, Jessica Foley, Tina Hollowell, and Chris McLaren will be on-site throughout the event and look forward to connecting with attendees.
Be sure to attend Chris McLaren’s presentations:
Pipes Acts of 2026
Tuesday, August 12 | 4:00 PM – 5:00 PM
DIMP
Wednesday, August 13 | 2:30 PM – 3:30 PM
Stop by and visit with our team to discuss pipeline safety, compliance, integrity management, and the latest industry developments.
PSI Training Schedule
|
DATE |
COURSE | FEE |
|
Aug. 4-6, 2026 |
DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 & 199) |
$2,150 |
|
Sep. 22-24, 2026 |
Pipeline Safety Audit Training (Comprehensive training with technical and soft skills) |
$2,150 |
| Nov. 17-19, 2026 |
DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 & 199) |
$2,150 |
FREE LIVE WEBINAR ALERT!
Unpacking the Key Updates in API RP 1170 & 1171, 2nd Edition
Join RCP and the Pipeline Safety Institute for a FREE webinar exploring the 2nd Editions of API RP 1170, Design and Operation of Solution-mined Salt Caverns Used for Natural Gas Storage and API RP 1171, Functional Integrity of Natural Gas Storage in Depleted Hydrocarbon Reservoirs and Aquifer Reservoirs.
On July 22, industry experts Phil Baker and Stephen Nowaczewski will discuss key updates, compliance practices and evaluate how their existing programs align with the revised requirements.
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.