April 2024 Issue
In This Issue
- April is Safe Digging Month!
- PHMSA Extends Feedback Deadline for GPAC Public Meeting Proceedings
- Arkansas Rule D-23 – General Rule for the Regulation of Underground Natural Gas Storage Projects
- Missouri Updates Department of Commerce and Insurance Rules: What You Need to Know!
- Featured Service
- Summary of Proposed PHMSA Form Updates
- Q&A Section
- Did you know?
- The Enforcement Corner
- 2026 Conference News
- PSI Training Schedule
April is Safe Digging Month!
April marks an important time of the year as it is designated as Safe Digging Month, a period dedicated to raising awareness about the importance of safe digging practices and preventing underground utility damage.
Think again. 40% of active diggers don’t contact 811 before digging because they think their project is too shallow to require it.
The truth is, utilities can be buried just inches below the surface. The only way to know for sure is to contact 811 before any digging project. Contact www.811beforeyoudig.com.
PHMSA Extends Feedback Deadline for GPAC Public Meeting Proceedings
PHMSA has published the voting slides and transcripts from the March 25– 29 GPAC meeting, which covered the NPRM for Class Location Change Requirements and the NPRM for Gas Pipeline Leak Detection and Repair. Those slides and meeting transcripts can be found here.
On April 10, 2024, PHMSA extended the comment submission deadline for the proceedings of the GPAC by 120 days for the Class Location Change Requirements NPRM. However, the submission deadline for comments on the Gas Pipeline Leak Detection and Repair NPRM were not extended and remains as April 29, 2024.
Arkansas Rule D-23 – General Rule for the Regulation of Underground Natural Gas Storage Projects
The Arkansas Oil and Gas Commission (“OGC”) has proposed amendments to Commission General Rule D-23, “General Rule for the Regulation of Underground Natural Gas Storage Projects.” Specifically, the rule amendments are promulgated to provide for the underground storage of other gases, such as carbon oxides, ammonia, hydrogen, nitrogen, and noble gas. The OGC accepted comments up until April 15, 2024. Interested parties can review the redlined proposed general rule in person at the OGC offices in North Little Rock, Arkansas, at 5301 Northshore Drive, phone 501-683-5816; or online at the OGC website.
Underground Gas Storage
RCP is the market leader for underground gas storage integrity and risk management. We have unmatched industry leaders available to assess your program and provide practical feedback and recommendations for improving your gas storage integrity and risk programs. For more information about RCP’s underground gas storage integrity management and risk analysis services, visit our website or contact Jessica Foley.
Missouri Updates Department of Commerce and Insurance Rules: What You Need to Know!
The State of Missouri has amended the rules in the Department of Commerce and Insurance, Division 4240 – Public Service Commission, Chapter 40 – Gas Utilities and Gas Safety Standards, effective March 1, 2024. These rule changes address amendments by the Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety, 49 CFR Parts 191 Transportation of Natural and Other Gas by Pipeline; Annual, Incident , and Other Reporting, and 192 Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards, promulgated between January 2021 and December 2023 (i.e., RIN 3, RIN 2, RMV). The State of Missouri regulations now match those of PHMSA. This amendment also incorporated by reference the most recent version of 49 CFR Parts 40 and 199, Drug and Alcohol Testing. Below is a list of some of the additional State requirements that have been revised:
- Affiliate Transactions
- Marketing Affiliate Transactions
- HVAC Services Affiliate Transactions
- Natural Gas Price Volatility Mitigation
- Immediate Notice of Missouri Incidents
- Estimated property damage of $17,500
- Submittal of Welding/Joining Procedures and Construction Standards
- Uniform System of Accounts-Gas Corporations
- Filing Requirements for Gas Utility Rate Schedules
- Submission Requirements for Gas Utility Depreciation Studies
For a copy of the Missouri Safety Standard, contact Jessica Foley.
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
Summary of Proposed PHMSA Form Updates
[Docket No.: PHMSA-2022-0085]
Stay in the loop with the latest PHMSA proposed form changes as of March 25, 2024. Our summary provides essential insights to keep you informed and prepared.
- Operator ID Request & National Registry Notification Forms
PHMSA has added an option for Blended Natural Gas and Hydrogen Gas – a natural gas stream which is blended by intentionally injecting hydrogen gas into the stream at varying percentages. - Gas Distribution, Gas Gathering & Transmission Incident Reports
PHMSA proposes to add a question on the natural gas incident reports regarding Blended Natural Gas and Hydrogen Gas and the percentage by volume of hydrogen gas transported. - Gas Distribution, Gas Gathering & Transmission Annual Reports
PHMSA proposes to add Blended Natural Gas and Hydrogen Gas to the commodity groups that can be selected in the Natural Gas Annual Reports.
The Gas Gathering & Transmission Annual Report will require miles of pipe between a set of RMVs or alternative equivalent technologies to be entered in PART U – Miles of Onshore Pipe by Shut-Off Segment, Class Location, HCA, and Nominal Pipe Size. - Hazardous Liquids Annual Report
Miles of pipe between a set of RMVs or alternative equivalent technologies are to be entered in PART S – Miles of Onshore Pipe by Shut-Off segment, HCA, and Nominal Pipe Size.
For a copy of this notice from the Federal Register, please contact Jessica Foley.
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: Do I have to do ILI on newly constructed pipe?
A: Yes, hydro is the baseline – don’t have to ILI new construction.
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 have 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.
Did you know?
The American pharmaceutical and healthcare sectors could not continue to operate as they do without natural gas and other petrochemicals. The loss of these vital feedstocks and energy sources would cripple the production of vital supplies, make sanitary care vastly harder, and raise the cost of pharmaceuticals for customers. Learn more about the critical role natural gas plays in the pharmaceutical and healthcare sectors here: Advancing America’s Pharmaceuticals: The Value of Natural Gas to U.S. Pharmaceutical Manufacturing.
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 February 2024, PHMSA issued 1 CAO, 6 NOAs, 6 NOPVs, and 6 WLs accompanied by $307,942 in proposed fines. Significant proposed fines were attributed to the following code sections:
- $239,142 – 49 CFR 195.446(a) – Control Room Management
- $68,800 – 49 CFR 192.5(b)(3)(ii) – Class Locations
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 (NOPSO) 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.
2026 Conference News
Pipeline Pigging & Integrity Management
January 19-22, 2026 | George R. Brown Convention Center | Houston, TX
Since 1989, attendance at the annual PPIM Conference and Exhibition in Houston has grown from a few hundred to more than 4,000, including a commercial exhibition that began with a handful of specialized solution-providers and which now involves more than 190 companies and industry organizations from more than 25 countries.
Click here to register for PPIM 2026.
PSI Training Schedule
|
DATE |
COURSE | FEE |
|
|
Advanced DOT Pipeline Compliance Workshop -SOLD OUT- (49 CFR 192 & 195) |
|
|
|
DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 & 199) |
|
| 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 |
| On-Demand | Texas Pipeline Weatherization Fundamentals | $200 |
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.