Uncategorized

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 November 2025, PHMSA issued 1 NOA and 5 NOPVs accompanied by $276,400 in proposed fines. Please note: RCP maintains a detailed database of all PHMSA enforcement actions…

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…

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…

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…

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 October 2025, PHMSA issued 2 NOAs, 3 NOPVs, 1 PSO, and 5 WLs accompanied by $1,183,700 in proposed fines. Please note: RCP maintains a detailed database of…

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. Please note: RCP maintains a detailed database of all PHMSA…

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. 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…

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…

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. InIn July 2025, PHMSA issued 10 NOAs, 6 NOPVs, and 3 WLs accompanied by $62,900 in proposed fines. Please note: RCP maintains a detailed database of all PHMSA…

USDOT Introduces Data-Driven Enforcement Priorities to Strengthen Pipeline Safety

On July 22, 2025, PHMSA announced pipeline inspection and enforcement (I&E) priorities.  This is something new for PHMSA.  The memo directs PHMSA I&E staff to concentrate their efforts on five priority areas: PHMSA I&E staff will also prioritize inspections to confirm operator compliance with recent rulemakings. These include requirements for:

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 June 2025, PHMSA issued 1 NOA, 3 NOPVs, and 2 WLs accompanied by $188,600 in proposed fines. Please note: RCP maintains a detailed database of all PHMSA…

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…

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…

PHMSA Form Updates

PHMSA has released updates to several key forms. The most recent changes went into effect on July 7, 2025, and include the following: Earlier updates were also made on April 29, 2025, affecting both registration and reporting forms: Operators should ensure they are using the latest versions when submitting documentation to PHMSA.

PHMSA Rescinds ADB-2021-01

On June 13, 2025, PHMSA rescinded ADB-2021-01—and any PHMSA policy statements, letters of interpretation, guidance documents, congressional testimony, and public statements that rely on or assert the reading of the section 114 mandate expressed in ADB-2021-01.  Owners and operators of pipeline facilities should adhere to the text of section 114 of the 2020 PIPES Act…

ANPRM: Pipeline Safety: Repair Criteria for Hazardous Liquid and Gas Transmission Pipelines

[Docket No. PHMSA-2025-0019] PHMSA published an advance notice of proposed rulemaking (ANPRM) on May 21, 2025, to gather stakeholder feedback on potential amendments to Parts 192 and 195 including repair timelines, remediation criteria, integrity management rules, and re-assessment intervals to ensure regulations maintain pace with modern technology and best practices without imposing unnecessary burdens. Additionally, PHMSA is…