February 2026 Issue
In This Issue
PHMSA Issues Advisory on Plastic Pipe Risks in Gas Distribution Systems
[Docket No. PHMSA-2026-0166]
PHMSA has issued an advisory bulletin reminding natural gas distribution operators to fully address risks associated with plastic piping and components under existing Distribution Integrity Management Program (DIMP) requirements. The advisory follows a 2023 gas explosion in West Reading, Pennsylvania, linked to degradation of older plastic components exposed to elevated temperatures. PHMSA emphasizes that operators must understand where plastic pipe exists in their systems, recognize how environmental factors can accelerate degradation, and ensure those risks are reflected in their integrity management plans.
PHMSA outlines several actions operators should consider to reduce risk, including:
- Inventorying plastic pipe and components susceptible to degradation
- Identifying environmental conditions such as elevated temperatures or nearby utilities
- Evaluating and ranking risks associated with plastic materials
- Increasing monitoring, inspections, or leak surveys where appropriate
- Repairing, remediating, or replacing problematic components
While the advisory does not introduce new regulatory requirements, it reinforces that operators must use reasonably available information to meet current DIMP obligations and proactively manage threats related to plastic piping to prevent leaks, failures, and potential incidents.
For a copy of this advisory bulletin, please contact Jessica Foley.
PHMSA Issues Guidance on Type-A Sleeve Risks for Hazardous Liquid Lines
[Docket No. PHMSA-2026-0298]
PHMSA has published an advisory bulletin focused on integrity risks linked to Type-A repair sleeves used on hazardous liquid pipelines. These sleeves consist of two steel halves welded around a pipe defect to reinforce it, but PHMSA notes that past failures, often tied to improper installation, moisture getting inside, and poor assessment practices, have led to environmental damage and costly incidents. The bulletin stresses that operators need to understand and manage these risks so that repair sleeves don’t become a source of corrosion or other long-term integrity problems.
PHMSA also reminds operators that existing safety regulations require thorough recordkeeping, inspection, and monitoring when relying on Type-A sleeves, even though the bulletin doesn’t prohibit their use. It’s meant as guidance to help operators spot potential issues early and make smart decisions about assessment, maintenance, and sleeve management to better protect people and the environment.
For a copy of this advisory bulletin, please contact Jessica Foley.
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.
Have questions about an upcoming deadline? Please reach out to Jessica Foley for assistance!
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 January 2026, PHMSA issued 3 CAOs, 3 NOPVs, and 2 WLs accompanied by $195,700 in proposed fines.
- $46,600 – §195.402(a) – Procedure Manual
- $55,900 – §195.444(b) – Leak Detection
- $46,600 – §195.452(b)(5) – Integrity Management Program
- $46,600 – §195.452(h)(4)(i)(A) – Integrity Management Program
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.
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.
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.
2026 Conference News
TGA Distribution Roundtable
February 24-25, 2026 | Decatur Conference Center | Decatur, TX
This gathering of the best minds in the industry encourages discussions on the current state and federal regulations, best practices, and new technologies, and allows for the face-to-face exchange of information and ideas on what works and what doesn’t.
Click here to register for the TGA Distribution Roundtable.
Speaker Announcement
Mr. Chris McLaren, Executive Consultant
“A Fair Price: Gas Distribution Rates Supported by Risk Analysis“
Chris McLaren will present on RCP’s experience supporting gas distribution operators in rate case justifications using Distribution Integrity Management Program (DIMP) risk models, along with repair and replacement data. The presentation will demonstrate how DIMP findings and mitigation actions can be used to support an operator’s request for cost recovery through gas distribution rates.
The session will highlight the importance of data-driven, risk-based justification to establish appropriate rates that sustain system safety, reliability, and the level of service customers expect.
NDSD Pipeline Safety Operator Training
March 3, 2026 | North Dakota Heritage Center | Bismark, ND
The operator training is a hands-on opportunity that prepares pipeline operators and safety personnel to work safely and in compliance with industry standards and regulations. It covers key topics like hazard recognition, regulatory requirements, safety best practices, and operator qualification fundamentals. The goal is to boost skills, improve safety awareness on pipeline jobs, and help attendees meet state and federal pipeline safety requirements.
Please message us if you would like more information about this event.
PSI Training Schedule
|
DATE |
COURSE | FEE |
|
Feb 24-26, 2026 |
DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 & 199) |
$2,150 |
| March 26, 2026 | Pipeline Safety: Class Location Change Requirements | FREE WEBINAR |
|
Apr 14-16, 2026 |
DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 & 199) |
$2,150 |
|
May 19-21, 2026 |
Advanced DOT Pipeline Compliance Workshop (49 CFR 192 & 195) |
$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 |
| 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.