DOT Pipeline Compliance News

April 2026 Issue

In This Issue

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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.

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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.

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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.

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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.

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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

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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:

1. Pipeline operators may disagree in whole or in part with each proposed violation cited by PHMSA. 
2. Proposed Civil Penalties (PCP) may be reduced or eliminated before an enforcement action becomes final.
3. 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.
4. A Notice of Amendment (NOA) is frequently a result of a difference of opinion regarding written procedure requirements.
5. 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.
6. A Notice of Probable Violation (NOPV) is not proof that a violation actually occurred.
7. Proposed Compliance Orders (PCO) frequently document actions the pipeline operator already planned to do.
8. 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.

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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)

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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

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PSI Training Schedule

DATE	COURSE	FEE
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!

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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.

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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…

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We would welcome the opportunity to discuss our services with you.

Sincerely,

W. R. (Bill) Byrd, PE
President
RCP Inc.