January 2025 Issue
In This Issue
- PHMSA NPRM: Safety of Carbon Dioxide and Hazardous Liquid Pipelines
- Judicial Revisions to Gas Transmission Rulemaking
- PHMSA Published Onshore Gas Gathering FAQs for Type C and R Pipelines
- API On-Demand Webinar: Key Insights from API 1104, 22nd Edition Update
- Featured Service
- The Enforcement Corner
- Did you know?
- Q&A Section
- 2025 Conference News
- 2025 PSI Training Schedule
PHMSA NPRM: Safety of Carbon Dioxide and Hazardous Liquid Pipelines
[Docket No. PHMSA-2022-0125]
PHMSA has published a Notice of Proposed Rulemaking (NPRM) with revisions to the Pipeline Safety Regulations to enhance safety standards and reporting requirements for gas- and liquid-phase carbon dioxide pipelines. Key changes include establishing an emergency planning zone for improved response and public communication, more prescriptive fracture control requirements, explicit inclusion of carbon dioxide in the definition of a highly volatile liquid, specific vapor dispersion modeling requirements, and updates to operations, maintenance, and emergency manuals. Additional measures apply to hazardous liquid and carbon dioxide pipelines, such as enhanced right-of-way inspections for geologic hazards, fixed vapor detection and alarm systems at specific facilities, and changes to conversion-to-service requirements.
RCP will release a special edition newsletter analyzing the revised NPRM. To request a copy of this NPRM, please message Jessica Foley.
Judicial Revisions to Gas Transmission Rulemaking
PHMSA has made amendments conforming Part 192 of the Code of Federal Regulations (CFR) to the August 2024 order of the United States Court of Appeals for the District of Columbia Circuit by removing several vacated provisions. On August 24, 2022, PHMSA published a final rule titled “Safety of Gas Transmission Pipelines: Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments” amending the federal pipeline safety regulations at 49 CFR Part 192 to improve the safety of onshore gas transmission pipelines.
The Interstate Natural Gas Association of America (INGAA) filed a petition for judicial review challenging several provisions of the 2022 Gas Transmission Final Rule. On August 16, 2024, the United States Court of Appeals for the District of Columbia Circuit (D.C. Circuit) ordered the following provisions vacated: 1) Monitoring and mitigation of internal corrosive constituents at § 192.478; 2) The immediate repair criterion for cracks or crack-like anomalies with predicted failure pressures below 1.25 x maximum allowable operating pressure (MAOP) at §§ 192.714(d)(1)(v)(C) and 192.933(d)(1)(v)(C); and 3) High-frequency electric resistance welded seams as one of the seam types qualifying for the immediate repair criterion of preferential metal loss on certain seam types at §§ 192.714(d)(1)(iv) and 192.933(d)(1)(iv).
These amendments conform the PHMSA regulations in the CFR with the court’s decision.
PHMSA Published Onshore Gas Gathering FAQs for Type C and R Pipelines
On January 14, 2025, PHMSA released the Onshore Gas Gathering FAQs for Type C and Type R Pipelines. This comprehensive compilation offers crucial guidance on gas gathering operations and outlines the specific regulatory requirements for Type C and Type R gathering lines. To request a copy of the FAQs, please contact Jessica Foley.
API On-Demand Webinar: Key Insights from API 1104, 22nd Edition Update
API hosted an in-depth webinar on January 9th, focusing on the 22nd Edition of API Standard 1104, Welding Pipelines and Related Facilities. Presented by the API/AGA Joint Committee on Pipeline Field Welding Practices, this session covered the key updates and improvements in the latest edition of the standard. Attendees learned about the rationale behind these changes and had the opportunity to engage in a live Q&A with industry experts. The webinar is highly relevant for operating companies, contractors, and regulators involved in pipeline welding.
For those who missed the live session, the recording is now available on API’s Learning website.
Featured Service
TaskOp Highlight: MOC Module
TaskOp, RCP’s reliable Workflow & Asset Management Application, features a fully integrated Management of Change (MOC) module. Designed to meet the requirements of 49 CFR 192, 195, and PHMSA’s RIN2, Gas Mega Rule regulations as documented in § 192.13, this module allows users to electronically oversee their company’s management of change process.
TaskOp’s MOC module was built to manage the following aspects of any MOC process:
- Scalable approval process, with designated alternates
- Tracking of MOCs through a step-by-step process flow
- Set automatic notifications to key personnel for each process step
- Allows MOC Coordinator to track real time updates and progress of MOC
- Provides checks and balances for modifications of process to ensure MOC security
- Comprehensive documentation of change (TVC)
TaskOp’s MOC module was specifically designed to provide ease of use while being flexible and scalable, offering robust customization options to meet increasing regulatory requirements. This module ensures a consistent and reliable experience throughout any MOC process.
If your goal is a streamlined and accessible MOC process, look no further than TaskOp’s MOC module.
From 49 CFR 192.13: “For pipeline segments other than those covered in subpart O of this part, this management of change process must be implemented by February 26, 2024. The requirements of this paragraph (d) do not apply to gas gathering pipelines.”
To learn more about the TaskOp MOC module, click the link below to schedule a demo.
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 2024, PHMSA issued 7 NOA, 6 NOPV, and 1 WL accompanied by $199,700 in proposed fines. Significant proposed fines were attributed to the following code sections:
- $39,100 – §192.705(a) – ROW Patrols
- $43,500 – §195.412(a) – ROW Inspections
- $66,900 – §192.303 – Compliance with Specifications
- $50,200 – §192.745(b) – Valve Maintenance
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 Version, 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: Does any portion of a 192.635 “Notification of Potential Rupture” require OQ training as a covered task?
A: Yes, 192.635 “Notification of Potential Rupture” implicitly requires that employes and contractors who work along the ROW (or who remotely monitor pipelines) are able to identify potential ruptures and know how to respond. This competency should be incorporated into the operator’s Operator Qualification (OQ) program, as well as into Control Room Management (CRM) training.
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.
2025 Conference News
APGA Operations Conference 2025
October 21-October 23, 2025 | Sheraton Hotel Charlotte | Charlotte, NC
This event typically attracts over 250 natural gas distribution industry professionals from more than 70 public gas systems to learn about topics such as PHMSA’s Natural Gas Distribution Infrastructure Safety and Modernization Grant Program, methane emission mitigation strategies, and new technology along with an exhibitor hall.
Click here to register for APGA’s Operations Conference.
2025 PSI Training Schedule
| DATE | COURSE | LOCATION |
| Nov 18-20, 2025 |
Advanced DOT Pipeline Compliance Workshop (49 CFR 192 and 195) |
Houston, TX |
| Jan 27-29, 2026 |
DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 and 199) |
Houston, TX |
| On-Demand |
DOT Pipeline Compliance Workshop (49 CFR 191, 192, 194, 195 and 199) |
Online |
| On-Demand |
Fundamentals of Pipeline Pressure Testing
(Gas & Liquid Pipelines) |
Online |
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.