December 2025 Issue
In This Issue
PHMSA Issues Limited Enforcement Discretion for API RP 1170 and 1171
On December 8, 2025, PHMSA issued a Notice of Limited Enforcement Discretion related to the Direct Final Rule titled “Pipeline Safety: Standards Update—API RP 1170 and API RP 1171.”
The rule, originally published on July 1, 2025, incorporates the second editions of API RP 1170 and API RP 1171 into 49 CFR Part 192, with an effective date of January 1, 2026.
Following requests from the American Gas Association and the Interstate Natural Gas Association of America, PHMSA recognized that operators and regulators need additional time to update procedures, complete training, and revise documentation. In response, PHMSA will exercise enforcement discretion through January 1, 2027.
During this period, PHMSA will not take enforcement action related to the Direct Final Rule as long as operators comply with either the first or second editions of API RP 1170 and API RP 1171. This approach is intended to support orderly implementation of the updated standards while maintaining an equivalent level of safety, particularly during upcoming winter heating seasons.
PHMSA has also encouraged state pipeline safety partners to apply the same enforcement discretion. This notice does not relieve operators from compliance with other applicable regulations, and PHMSA retains the authority to take enforcement action if significant safety concerns arise.
As operators work through these updates, TaskOp’s built-in Underground Gas Storage module can help manage API RP 1170 and 1171 requirements by organizing procedures, tracking changes, and centralizing documentation in one system. Click here for more information about the UGS module in TaskOp and feel free to contact Jessica Foley for a copy of the notice.
Leadership Update at PHMSA’s Office of Pipeline Safety
PHMSA has announced a leadership transition within the Office of Pipeline Safety. John Gale has retired from his role as Director of Standards and Rulemaking, concluding a long career in public service focused on pipeline safety and regulatory development.
Throughout his tenure, John Gale played a key role in shaping federal pipeline safety regulations and guiding the standards and rulemaking process through several major initiatives. His work helped provide regulatory clarity for operators while reinforcing PHMSA’s core mission of safety.
PHMSA has named Cameron Satterwhite as the new Director of Standards and Rulemaking. In this role, Cameron will oversee the development and implementation of pipeline safety regulations and standards, working closely with stakeholders across the industry and within the agency.
This transition marks both a moment of appreciation for John Gale’s contributions and a new chapter for the Office of Pipeline Safety as Cameron Satterwhite steps into this leadership role.
Have a couple minutes?
Take a quick look at our new video, “A Day in the Life with TaskOp.” It shows how teams use TaskOp to keep work organized, moving, and audit ready. After watching, let us know if this type of content is helpful and what else you’d like to see us create. Your feedback helps guide what we produce next.
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
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.
- $276,400 – §195.432(b) – Breakout Tank Inspections
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.
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.
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 here to learn more.
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
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Sincerely,
W. R. (Bill) Byrd, PE
President
RCP Inc.